Last updated: December 31, 2019

This “Privacy Policy” describes the privacy practices of Adamas Pharmaceuticals, Inc. and our subsidiaries and affiliates (collectively, “Adamas”, “we”, “us”, or “our”). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information in connection with the https://www.adamaspharma.com/ website and any other website that we own or control and which posts or links to this Privacy Policy (the “Sites”), and our products and services (together with the Sites, the “Services”), and explains the rights and choices available to individuals with respect to their information.

Adamas may provide additional privacy notices to individuals at the time we collect their data For example, we provide a specific privacy notice to clinical trial participants that describe our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide at that time.

 

Personal Information We Collect

Whose Personal Information We Collect

We collect personal information about the following types of individuals: clinical trial participants, patients, patient family members, caregivers or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, website users, job applicants, and other individuals who interact with us, our service providers or business partners.

How We Collect Personal Information

We collect personal information:

  • Directly from individuals
  • Through our Sites
  • From healthcare professionals
  • From contract research organizations and clinical trial investigators
  • From government agencies or public records
  • From third party service providers, data brokers or business partners
  • From industry and patient groups and associations
  • From social media or other public forums (including adverse event information or product quality complaints)
  • From former employers or references

Types of Personal Information We Collect

We may collect the following types of personal information:

  • Health and medical information, such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, and medications an individual may take, including the dosage, timing, and frequency, that we collect in connection with managing clinical trials, conducting research, providing patient support programs, managing compassionate use and expanded access programs, and tracking adverse event reports;
  • Contact information (personal and business), such as job title and employer name, email address, mailing address, phone number, and emergency contact information;
  • Biographical and demographic information, such as age, date of birth, gender, marital status, and information regarding any parents or legal guardians;
  • Professional credentials, such as educational and professional history, institutional affiliations, and other information you include on a CV or resume;
  • Payment-related information, such as when we need to pay for professional services that individuals may provide to us, such as tax identification number and financial account information;
  • Engagement data, such as information about the programs and activities in which you have participated, your prescribing of our products, your use of our products and the agreements you have executed with us;
  • Digital information, such as your photograph, social media handle or digital or electronic signature;
  • Publicly available information, such as comments describing support for and experience with our products, and other information you publish on social media (including Adamas social media pages);
  • Correspondence and other information you provide to us, including in emails, on phone calls, and in market research surveys;
  • Data collected automatically by us, our service providers, and third party partners, who may automatically log information about you, your computer or mobile devices, and your activity over time on the Sites and other online services, such as:
    • Device data that is collected automatically (such as your IP address, your device’s operating system, your Internet service provider and location, browser type and language, your unique device ID (persistent/non-persistent), hardware type, medial access control address and the website you visited before browsing to our Sites); and
    • Online activity data that is collected automatically (such as information about the Site content you access) and information about the date, time and duration of your visit to our Sites.
  • Job Applicants. When visit the careers portion of our Sites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to communicate with you, to operate and improve the Services, and as otherwise necessary for compliance, fraud prevention, and safety purposes.

Cookies and Similar Technologies

Some of our automatic data collection is facilitated by cookies and similar technologies. Cookies are small data files placed on your computer when you visit a site. We may set cookies when you use our Sites to understand how visitors are using the Sites, help you navigate between pages efficiently, remember your preferences and generally improve your browsing experience. Analytics service providers and advertising partners may also set cookies used on our Sites. In addition to cookies, our Sites and emails may use pixel tags (also known as web beacons and clear GIFs) to compile statistics about use of the Services, measure the success of our marketing campaigns, and indicate whether recipients of our emails open or click links within them.

How We Use Personal Information

We use personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To communicate with you, including to:

  • Provide you with investor, media or other materials;
  • Send you copies of our press releases or other information;
  • Send you surveys or other marketing communications; and
  • Respond to your comments, questions, and service-related requests.

To operate and improve the Services, including to:

  • Operate, maintain, administer and improve the Services;
  • Provide interactive features of the Sites;
  • Better understand your needs and interests, and personalize your experience with the Services; and
  • Provide support and maintenance for the Services.

To perform and administer clinical trials, research and product-improvement activities, including to:

  • Staff and manage clinical trials, including by recruiting investigators and participants;
  • Track and respond to safety and product quality concerns (including product recalls);
  • Support public health initiatives, symposia, conferences, and scientific, educational and volunteer events;
  • Define and manage appropriate patient engagement activities, and patient support programs (including to provide co-pay and other financial assistance where available);
  • Identify and engage thought leaders and external experts;
  • Award scholarships and grants; and
  • Attribute authorship to academic and promotional materials.

To provide our products and payments, including to:

  • Manage access to our products, including where access is limited by law to licensed physicians; and
  • Pay for services that physicians, researchers and other individuals may provide to us.

To display advertisements. We work with advertising partners to display advertisements on the Services. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes.

For compliance, fraud prevention, and safety. We may also use personal information as we believe necessary or appropriate to:

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • Comply with regulatory monitoring and reporting obligations, such as those related to adverse events, product complaints, safety, and financial disclosures;
  • Enforce the terms and conditions that govern our product candidate;
  • Protect our rights, privacy, safety or property, and/or that of you or others; and
  • Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Personal Information

  • We do not share personal information with third parties without consent, except in the following circumstances or as otherwise described in this Privacy Policy:

Affiliates. We may share personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may engage other companies and individuals to perform services on our behalf, including:

  • Companies that analyze data and provide business support (such as data storage and technology services);
  • Companies that support the quality and safety of our products;
  • Event planning and travel organizations that help facilitate our programs and services;
  • Companies that assist us in clinical research and development activities; and
  • Companies that support us in marketing and commercializing our products.

These service providers may have access to personal information in connection with performing services on our behalf. These service providers may use your information only as directed by Adamas and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Professional advisors. We may disclose personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Advertising partners. Third party advertising companies that collect information about your activity on our Sites and other online services to help us advertise our products and services.

Research and business partners. We may also share personal information with healthcare professionals, researchers, institutions, academics, public health organizations, and publishers for purposes consistent with this Privacy Policy. We may disclose personal information to partners or collaborators in connection with the research and development of our products.

Compliance, fraud prevention and safety. We may share personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Update your information. You may request that we update any information we maintain about you that is inaccurate or out-of-date by emailing us at privacy@adamaspharma.com.

Opt out of marketing communications and other sharing. You may opt out of marketing communications by following the opt-out or unsubscribe instructions within the communication (such as at the bottom of our marketing emails), or by contacting us at info@adamaspharma.com. You may also email us at info@adamaspharma.com to request to opt-out of our sharing your personal information with third parties for those parties own purposes (except where we share information as described in the Affiliates, Service providers, Professional advisors, Compliance, fraud prevention and safety, and Business transfers subsections of How We Share Personal Information).

Cookies. Most browsers let you remove and/or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. You may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative at http://www.networkadvertising.org/choices or the Digital Advertising Alliance at http://www.aboutads.info/choices. Please note that not all advertising companies participate in these opt-out programs above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

The Sites may contain links to other websites and online services operated by third parties. 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 web pages or other online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions.

Security Practices

In an endeavor to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we use a variety of industry-standard security technologies and procedures to help safeguard and secure personal information we collect from unauthorized access, use, or disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. We therefore cannot guarantee the security of any information that you disclose online, and you do so at your own risk.

International Data Transfers

We are located in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

We do not knowingly collect or solicit personal information from anyone under the age of 13 through our Sites, or knowingly allow such persons to use our Sites. In the event that we learn that we have collected personal information from a child under age 13 through our Sites, we will delete that personal information as soon as reasonably practicable.

Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Sites. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the Services. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Privacy Policy or our privacy practices to privacy@adamaspharma.com. You may also write to us via postal mail at:

Adamas Pharmaceuticals, Inc.
Attn: Legal – Privacy
1900 Powell Street, Suite 1000
Emeryville, CA 94608

Notice to California Residents

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of the personal information.

Under the CCPA, this Notice to California Residents and the privacy practices and rights it describes do not apply to the information we collect, use or disclose about clinical trial volunteers, candidates, participants and investigators, healthcare providers, and other individuals who represent businesses that provide services to us or to whom we provide our products or services. This is because information about these individuals is governed by clinical trial regulations, the California Confidentiality of Medical Information Act or the Health Insurance Portability and Accountability Act of 1996, or is subject to the CCPA’s exemption for business contact information.

Personal Information We Collect, Use and Share

We do not sell personal information. As we explain in this Privacy Policy, use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you would like to learn how you may opt out of our (and our third party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide.

In addition to the information in our Privacy Policy, the following chart further describes our privacy practices with respect to individuals whose information is not subject to the above exceptions and is governed by the CCPA, such as our individual investors, consumers and caregivers who visit our websites.

Personal information we collect CCPA-defined categories (click for details) Sources from which we may collect the personal information Purposes for which we may collect and use the personal information Categories of third parties to which we disclose the personal information
Personal and business contact information

Correspondence

Engagement Data

Identifiers

Commercial Information

Professional or Employment information

You To operate and improve the Services

To communicate with you

None
Device data
Online activity data
Inferences

Internet or Network Information

Online Identifiers

You

Automatic collection

To operate and improve the Services

To display advertisements

Advertising partners

Please note that we may also disclose all personal information for compliance, fraud prevention and safety, and in connection with business transfers, as described in the “How We Share Personal Information” section of the Privacy Policy

California Residents’ Privacy Rights

Except as excluded from the scope of this Notice (as described above), the CCPA grants individuals whose information is governed by the CCPA the following rights.

  • Information. You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months. We have made this this information available to California residents without having to request it by including it in this notice, in the above chart.
  • Access. You can request a copy of the Personal Information that we maintain about you.
  • Deletion. You can ask us to delete the Personal Information that we collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

You are entitled to exercise the rights described above free from discrimination.

How to Submit a Request

To request access to or deletion of personal information:

Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

Glossary

Statutory Category Data Elements within the Category
Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Identifiers Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Inferences The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Internet or Network Information Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement.
Online Identifiers An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
Professional or Employment Information This term is not defined in the CCPA, but likely includes any information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations).