Privacy Policy

Privacy Policy

Collegium Pharmaceutical, Inc. (“Collegium”) respects the privacy of information that it obtains from visitors to its websites (“Site”). Please read the following Statement to learn more about Collegium’s Privacy Policy.

Collegium’s most important asset is your trust. Keeping user-identifiable information secure is a priority for Collegium.

This Privacy Policy covers the following types of information:

  1. This Privacy Policy covers Collegium’s treatment of personally identifiable information that Collegium collects when you are on this Website; and
  2. This Privacy Policy does not apply to the practices of companies that Collegium does not own or control, or to people that Collegium does not employ or manage.

Information collection and use will be handled in the following manner:

  1. Collegium will take reasonable steps to safeguard any information you share with us. Collegium stores the information you provide about yourself in a database in order to provide you with the information you request. The information is stored for the lifetime of the database unless you request that it be removed;
  2. Collegium will limit the collection and use of your information to the minimum Collegium requires in order to advise you about Collegium’s products, services and other opportunities, and to administer Collegium’s business;
  3. This Site is not intended or designed to attract children under the age of 18. We do not knowingly collect personally identifiable data from Site visitors under the age of 18;
  4. Collegium will permit only authorized employees who are trained in the proper handling of third-party information to have access to that information. Employees who violate Collegium’s Privacy Policy will be subject to Collegium’s normal disciplinary process;
  5. Except as described above, Collegium will not otherwise use or disclose any of your personally identifiable information, except to the extent reasonably necessary: (i) to correct technical problems and malfunctions; (ii) to technically process your information and to determine the effectiveness of our projects; (iii) to protect the security and integrity of our website; (iv) to protect our rights and property and the rights and property of others; (v) to take precautions against liability; (vi) to the extent required by law or to respond to judicial process; or (vii) to assist enforcement agencies or for an investigation on a matter related to public safety, as applicable;
  6. Some of Collegium’s pages may use “cookies” – data that a website can send to your browser, which in turn is stored on your computer system. Collegium may set and access Collegium cookies on your computer. This information will be used to allow our Website to recognize you and provide customer information when or where appropriate. You can configure your browser to notify you when you receive a cookie or you can instruct your browser to refuse cookies altogether;
  7. As a resource to our visitors, Collegium may provide links to other websites. You should carefully review the privacy policies and practices of these websites, as Collegium cannot control or be responsible for their privacy practices;
  8. At any time, you can contact Collegium to remove your name from our database;
  9. For the purpose of determining the effectiveness of our Site, Collegium may hire certain organizations that collect, analyze and report on non-personally identifiable data or provide website support services. To the extent possible, Collegium will require these organizations to conform to Collegium’s Privacy Policy; and
  10. By using this Website and the contents available to you on our Website, you consent to our collection and use of your information as described above. Collegium will continuously assess its practices to ensure that your privacy is respected. Collegium may amend this Privacy Policy from time to time. If Collegium makes any substantial changes in the way Collegium uses your personal information, Collegium will notify you by posting a prominent announcement on Collegium’s Website.
  11. Personal information we collect
    “Personal Data” are information that identify you as an individual or relate to an identifiable individual, including:

    • Name;
    • Address;
    • Telephone number;
    • Email address;
    • Picture;
    • Gender;
    • Birthdate;

    We collect names and Email addresses to allow you to receive marketing information from our company.

  12. How we collect personal information
    We collect personal information through the information request form on our website. We may collect other information regarding your use of our services, including web logs and analytics information.
  13. The purpose of collection of the personal information.
    We may use Personal Data for our legitimate business interests. For example, we may collect your personal information to be able to understand regional sensitivity.
  14. With whom the information is shared with
    We do not sell your information to anyone. The personal information we collect is shared with business partners, third party application providers in the course of delivering services, and to third parties engaged to send you marketing communications.

Local specific information: Your Privacy Rights Under the California Consumer Privacy Act (“CCPA”)

  1. Access to Specific Information and Data Portability Rights
    The CCPA provides consumers (California residents) with rights regarding their personal information.
    You have the right to request that Collegium disclose certain information to you about our collection and use of your personal information over the past 12 months. Once Collegium receives and confirms your verifiable consumer request, we will disclose the following information to you:

    • The categories of personal information we collected about you.
    • The categories of sources for the personal information we collected about you.
    • Our business or commercial purpose for collecting that personal information.
    • The categories of third parties with whom we share that personal information
    • The specific pieces of personal information we collected about you (also called a data portability request).
    • If we disclosed your personal information for a business purpose, a list disclosing:
      • sales, identifying the personal information categories that each category of recipient purchased; and
      • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained
      • Although we do not sell Site users’ personal information, the CCPA also requires that, were we to do so, we disclose to you our business purpose for selling the information and provide a list disclosing the sales and identifying the personal information categories that each category of recipient purchased.
  1. Deletion Request Rights
    You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
    We may deny your deletion request if retaining the information is necessary for us or our service providers to:

    1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Debug products to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    8. Comply with a legal obligation.
    9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  1. Exercising Access, Data Portability, and Deletion Rights
    To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

    • Calling us at 781-713-3699
    • Emailing us at Compliance@collegiumpharma.com

    Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

    You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

  1. Response Timing and Format
    We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  1. Non-Discrimination
    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.