Privacy policy

I. Introduction

Alfasigma USA, Inc. (“Company” or “we”) respects your privacy and are committed to protecting it through our compliance with this Privacy Policy. This policy describes the types of information we may collect from you or that you may provide when you visit an Alfasigma USA website – www.alfasigmausa.com; www.deplin.com; www.metanx.com; www.cerefolinnac.com; www.cerefolin.com; www.neevodha.com; and www.proxeed.com (our “Website”, and collectively, “Websites”) – and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website. 
• In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third-party; or 
• Any third-party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this Website, you agree to this privacy policy. We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

II. Information

A. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including but not limited to the following information:

• By which you may be personally identified, such as first and last name, postal address, e-mail address, and telephone number (“personal information“); and 
• That is about you but individually does not identify you, such as languages you may speak and geolocation information; and/or 
• About your internet connection, the equipment you use to access our Website, and usage details. 

We collect this information:

• Directly from you when you provide it to us; 
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and 
• From third-parties, for example, our business partners. 

B. Information You Provide to Us

The information we collect on or through our Website may include: 

• Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you report a problem with our Website. 
• Records and copies of your correspondence (including email addresses), if you contact us. 

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third-parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. While we use technical, administrative, and procedural measures designed to safeguard your personal data from unauthorized access or use, no such measure is ever 100% effective, and therefore we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. If you submit any personal data relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We ask that you do not send us nor disclose any unsolicited sensitive personal information, including Social Security numbers, political opinions, religious or philosophical beliefs, sex life or sexual orientation, criminal background, biometric or genetic data for the purpose of uniquely identifying an individual.

C. Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. Information about your computer and internet connection, including your IP address, operating system, and browser type. The information we collect may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: 

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Website according to your individual interests; 
• Speed up your searches; and 
• Recognize you when you return to our Website. 

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. 
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and/or for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or that you provide to us.

III. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website 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 about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do 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 provider directly. 

A. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you; 
• To provide you with information, products, or services that you request from us; • To fulfill any other purpose for which you provide it; 
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; 
• To notify you about changes to our Website or any products or services we offer or provide through it; 
• In any other way we may describe when you provide the information; 
• For any other purpose with your consent; 
• To meet legal, security, processing, and regulatory requirements; and 
• To protect against fraudulent, suspicious, or other illegal activities. 

Where required by applicable law, we will obtain your consent for our use of your personal information at the point of information collection. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may provide functionality that allows you to share certain content with other individuals. If you choose to utilize this sharing function, we may use your data, as well as the data of the individual you are sharing said content with, to effectively send the content. Additionally, we may offer access to third-party sharing functionality, such as third-party social media widgets/tools/buttons. Your use of third-party sharing functionality subjects you to the third-party’s privacy policy and terms.

B. Disclosure of Your Information

We may create anonymous, aggregated or de-identified data from your personal data and that of other individuals whose personal data we collect. We may disclose aggregated information about our users without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates; 
• To contractors, service providers, and other third-parties we use to support our business; 
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred; 
• To fulfill the purpose for which you provide it; 
• For any other purpose disclosed by us when you provide the information; and/or 
• With your consent. 

We may also disclose your personal information: 

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request; and/or 
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. 

C. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly. 

We do not control third-parties’ collection or use of your information to serve interest-based advertising. However, these third-parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

IV. Children’s Privacy

Our Website is not directed at individuals under the age of 13 and we request that these individuals do not provide personal information to us. Without permission from a parent or legal guardian, we do not knowingly collect Personal Information directly from individuals under the age of 13. If we learn that we have collected Personal Information of individuals under the age of 13 through our Website, we will take appropriate steps to address this matter. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info.us@alfasigma.com.

V. Other Sites, Mobile Applications and Services

Our Website may contain links to other websites, mobile applications and services. These links are not an endorsement of, or representation that we are affiliated with any third-party. In addition, our content may be included on websites or in mobile applications that are not associated with us. We do not control third-party websites or mobile applications and are not responsible for their actions. Other websites and mobile applications follow different rules regarding the collection, use and sharing of your personal data. We encourage you to read the privacy policies of the other websites and mobile applications you visit.

VI. Data Processing

The information on the Website is intended for use by U.S. residents only. The Website may contain information about products not available in other countries. Other countries may have laws, regulatory requirements and medical practices that differ from those in the United States and may require different or additional information. Therefore, product information may not be appropriate for residents of other countries.

VII. International Data/Cross Border Transfers

The Website is controlled and operated from the United States and is not intended to subject the Company to the laws or jurisdiction of any other country or territory other than that of the United States. We may need to send your personal information overseas as part of the Company’s normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that the Company takes reasonable steps to ensure that your privacy is protected. However, the Company will handle your personal information in accordance with this privacy policy regardless of where your personal data is stored/accessed.

VIII. Data Retention and Deletion Requests

The Company retains personal information for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. When no longer needed, the Company will either de-identify the information or securely destroy the information. In some circumstances, we may de-identify your personal data in which case we may use this information indefinitely without further notice to you. This does not affect your right to request that we delete your personal data before the end of its retention period. Refer to Section X, below, for more information on how to submit requests to delete, copy and/or know Personal Information about you.

IX. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes. Continued use of our Website following any changes to this Privacy Policy indicates your consent to the use of newly submitted information in accordance with the amended Privacy Policy.

X. Submitting Personal Information Requests

You may submit requests to delete, copy and/or know Personal Information about you by emailing us at info.us@alfasigma.com. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information.

We may ask you to provide sufficient information in accordance with specific State laws that allows us to reasonably verify your identity, confirm that you are the person about whom we collected Personal Information or an authorized representative, and detail your request with sufficient information that allows us to properly understand, evaluate, and comply with your data information request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request, and confirm the Personal Information relates to you. We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.

To designate an authorized agent, email us at info.us@alfasigma.com. You may also make a request to know or delete on behalf of your child by emailing us at info.us@alfasigma.com. We will respond to your request consistent with applicable State laws.

The following provisions supplement the Alfasigma Privacy Policy with respect to specific rights afforded to individuals residing in certain states.

XI. California Residents

The following provisions apply to the Personal Information (as defined by Cal. Civ. Code § 1798.80(e)) of California residents processed by the Company collected via the Website. These provisions supplement the other sections of the privacy policy. We do not sell or share personal information of California residents. However, we may share or process your personal information with our affiliates and trusted partners in arrangements that may meet the definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.

A. Appendix A: Categories of Personal Data That We Collect and Disclose

Listed below are the categories of Personal Information about California residents that we collect and disclose for a business purpose. For more information about the categories of third-parties with whom we share your personal data, refer to the How We Use Your Information Section above. In particular, we have collected the following categories of Personal Information from our consumers within the last twelve (12) months:

As described in the Privacy Policy, Section II: Information We Collect About You and How We Collect It, we collect this Personal Information from you and from other sources, including public databases, social media platforms, and other third parties, when they share the information with us.

Also as described in the Privacy Policy, Section III: How We Use Your Information, we may use this Personal Information to operate our business; to deliver services, products, and information; to maintain and improve our website; to communicate with you and complete and fulfill your requests; to perform and enforce contracts; to tailor marketing programs and campaigns and conduct market research; for compliance and legal interests; and in association with mergers and acquisitions.

B. Individual Rights

You have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Policy. To exercise your CCPA rights, contact us at info.us@alfasigma.com.

Subject to certain exceptions, California residents have the right to make the following requests:

Copy: You may request a copy of the specific pieces of Personal Information that we have collected about you in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.

Correction: You may request correction of your personal data that we have collected about you if it is inaccurate or incomplete.

Deletion: You may request deletion of your personal data that we have collected about you. We may deny your deletion request if retaining the information is necessary for us or our service providers, and we will explain to you the reason for which it was necessary to retain it.

Know: You may request that we provide you certain information about how we have handled your personal data in the prior 12 months, up to twice per year, including the:

• categories of personal data collected; 
• categories of sources of personal data; 
• business and/or commercial purposes for collecting your personal data; 
• categories of third parties/with whom we have disclosed or shared your personal data; and 
• categories of personal data that we have disclosed or shared with a third party for a business purpose. 

Limit: You may request we limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law.

Opt-Out of the Sale of Personal Information: You may request to opt-out from the future “sale” or “sharing” of personal information as those terms are defined by the CCPA. You may also exercise this right by clicking on the “Do Not Sell or Share My Personal Information” link at the bottom of our websites.

Rights Under California’s “Shine the Light” Law: California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes to annually request, free of charge, information about the personal information (if any) disclosed to third parties for their direct marketing purposes in the preceding calendar year.  To make such a request, please contact us at info.us@alfasigma.com. Please note that businesses are required to respond to one request per resident per year and may not be required to respond to requests made by means other than through the designated email address listed above. We will not discriminate against you for exercising these CCPA rights.

XII. Colorado

If you are a Colorado resident, the processing of personal information about you is subject to the Colorado Privacy Act (“CPA”), which affords you certain rights with respect to your personal information. To exercise your CPA rights, contact us at info.us@alfasigma.com.

A. Individual Rights

Subject to certain exceptions, Colorado residents have the right to make the following requests:

Know: The right to confirm whether or not we are processing your personal information and to access such data;

Copy: The right to a portable copy of the personal information we have collected from you;

Delete: The right to request deletion of personal information about you, subject to certain exceptions;

Correct: The right to request correction of inaccurate personal information about you, taking into account the nature of personal information and purposes of processing such information;

Opt-Out of Targeted Advertising: The right to request we stop future processing of personal information about you for such purposes; and

Opt-Out of the Sale of Personal Information: The right to request we stop future processing of personal information about you for such purposes. You may also exercise this right by clicking on the “Do Not Sell or Share My Personal Information” link at the bottom of our websites. 

B. Appealing Our Decisions Made in Response to Your Requests

In some cases, we may not act on your requests (for example, if another law applies that prevents us from deleting a piece of personal information). When this is the case, we will explain our reasons for not providing you with the information or taking the action you requested. Additionally, you have the right to appeal our decision by emailing us at info.us@alfasigma.com. As part of your appeal, we may request you provide us with additional information that we may need (such as a reference number) to identify the particular request denial.

C. Additional Information About Colorado Privacy Rights

You may designate an agent to submit opt-out requests on your behalf under the CPA. If you use an agent to submit such requests on your behalf, we will need to verify your identity and obtain your signed permission indicating the agent has been duly authorized to submit the request on your behalf.

In order for us to provide, correct, or delete certain pieces of personal information, we may need to verify your identity.

We will not discriminate against you for exercising these CPA rights. 

XIII. Connecticut, Utah, Virginia and Washington Residents

Unless specifically stated, we do not sell or share personal information to third-parties for their own use. However, we may share or process such personal information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell” “share” “process” and “targeted advertising” are defined in the VCDPA, UCPA, WPA and CTDPA. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.

If you are a resident of a state with an applicable consumer health privacy law, you may have certain rights to access, delete or withdraw consent relating to your data, subject to certain exceptions. You can request to exercise such rights by emailing us at info.us@alfasigma.com. If you are dissatisfied with the Company’s decision, you can raise a concern or lodge a complaint with your state’s regulatory authority.

XIV. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: info.us@alfasigma.com

XV. Cookie Policy

This Cookie Policy is an integral part of Alfasigma USA Inc.'s (“Company” or “we”) Privacy Policy available on our Websites. The Website collects information that may concern the user, their preferences, or the Internet access device (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to the user's expectations, offering a better browsing experience and to send personalized promotional messages.

A. What are Cookies

Cookies consist of portions of code installed inside the browser that assist the site owner in providing the service according to the purposes described.

Thanks to Cookies, the site stores some information that is then retransmitted when the user returns to the site or navigates from one page to another. Cookies are also usually used to store anonymous information relating to page navigation (entry and exit links, dwell time), monitor and analyze the performance, operation and effectiveness of the site, in order to improve and optimize it. Some of the purposes for which cookies are installed may also require your consent.

B. Categories Of Cookies

1. Technical Cookies

These are cookies that are used to navigate or provide a service requested by the user. They are not used for further purposes and are normally installed directly by the owner of the website. Without the use of such cookies, some operations could not be carried out or would be more complex and/or less secure, such as for example the activities for which cookies, which allow the user's identification within the session, are indispensable. This type of cookie is strictly necessary for the correct functioning of certain sections of the site. There are two categories:

• persistent: once the browser is closed they are not destroyed but remain until a preset expiration date
• session: are destroyed every time the browser is closed.

These cookies, always sent from our Website, are necessary to correctly display the site and in relation to the technical services offered, will therefore always be used and sent, unless users change the settings in their browser (thus affecting the display of the site pages).

2. First Party Analytical Cookies

Cookies in this category are used to collect information about the use of the site.

These are cookies used for site optimization purposes directly by the Website owner, which collect information in aggregate form on the number of users and how they visit the site.

3. Third party Analytical Cookies with Reduced Identification Power

Cookies in this category are used to collect information about the use of the site. These are cookies created and made available by third parties for mere statistical purposes that adopt suitable tools to reduce the identification power of the analytical cookies they use (for example, by masking significant portions of the IP address).

4. Third Party Analytical Cookies without reduced identification power

Cookies in this category are used to collect information about the use of the site. They are cookies created and made available by third parties for mere statistical purposes that do NOT adopt suitable tools to reduce the identification power of the analytical cookies they use (for example, by masking significant portions of the IP address).

5. First Party Profiling Cookies

These are the cookies used by the owner of the website to track the user's navigation on the web and create profiles on his tastes, habits, choices, etcetera. With these cookies, advertising messages can be transmitted to the user's terminal in line with the preferences already expressed by the user when browsing online.

6. Third Party Profiling Cookies

These are the cookies used by third parties to track the user's navigation on the web and create profiles on their tastes, habits, choices, etc. With these cookies, advertising messages can be transmitted to the user's terminal in line with the preferences already expressed by the user when browsing online.

C. Disagreement With Use of Cookies

Upon entering this Website, you have the opportunity to confirm, reject or customize our use of cookies for specific purposes. If you confirm, you accept the use of cookies that will allow you to use all functions without restrictions when you visit our Website. If you reject all, this may affect your user experience and functionality while using the Website. We are not able to delete any third-party cookies. Therefore, you must delete third party cookies on your own. This can be done within your browser settings:

• Disable and/or delete cookies through your browser 
• In alternative and/or in addition, you can change the cookie settings in your browser. Your internet browser allows you to change your cookie settings.

D. Third-Party Cookies

The cookie settings on your browser are generally accessible under "options", "tools" or "preferences" in the internet browser menu. You can also consult the "help" item in the browser menu. Different browsers may have different mechanisms to disable cookies.

Please see the links below for more details on how to manage your cookie settings:

• Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies 
• Chrome: https://support.google.com/chrome/answer/95647?hl=en 
• Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectlocale=en-US&redirectslug=enable-and-disable-cookies-website-preferences

• Safari: https://support.apple.com/it-it/guide/safari/sfri11471/mac

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