LUPIN PRIVACY STATEMENT: SOLOSEC

Effective Date: 06/17/2024

You care about the protection of your Personal Information - and so do we. At Lupin Pharmaceutical, Inc. (USA) ("Lupin"), we work to maintain the privacy and data security of all Personal Information we collect or receive from you, including when you use our website for Solosec at www.solosec.com and https://www.solosechcp.com/ (together, the "Website").

This Privacy Statement ("Statement") applies to Personal Information Lupin collects, uses or shares, including when you visit the Website. Please read this Statement carefully. Should you have any questions about this Statement or how we handle Personal Information, please contact us at complianceandethicsoffice@lupin.com.

We may modify this Statement at any time. All changes will be effective immediately upon posting to the Website. Material changes will be conspicuously posted on the Website or otherwise communicated to you.

IF YOU ARE A CALIFORNIA, CONNECTICUT, OR TEXAS RESIDENT, PLEASE SEE SECTION 12 BELOW FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.

IF YOU ARE A WASHINGTON OR NEVADA RESIDENT, PLEASE SEE THE OUR CONSUMER HEALTH PRIVACY STATEMENT FOR INFORMATION ABOUT OUR PRACTICES IN HANDLING CONSUMER HEALTH DATA AS DEFINED UNDER APPLICABLE LAW.

IF YOU PROVIDE PERSONAL INFORMATION WITH REGARD TO OUR PHARMACOVIGILANCE PROGRAM, PLEASE SEE OUR PHARMACOVIGILANCE PRIVACY STATEMENT WHICH DESCRIBES HOW WE COLLECT, USE AND SHARE THE PERSONAL INFORMATION YOU PROVIDE IN CONNECTION WITH THAT PROGRAM.

1. WHAT IS PERSONAL INFORMATION?

"Personal Information" (which we also refer to as "Personal Data") is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information does not include publicly available information or aggregated information that does not include personal identifiers.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We have collected the following categories of Personal Information from consumers within the twelve (12) months preceding the effective date of this Privacy Statement:

3. WHAT ARE THE SOURCES OF PERSONAL INFORMATION WE COLLECT?

We collect or have collected Personal Information from the following sources:

Information You Provide to Us

We collect Personal Information you provide to us in the following ways:

  • When You Communicate with Us. When you communicate with us by calling us, writing us, emailing us through our "Contact Us" webpage.
  • Drug Safety Information and Concerns. When you seek drug safety information or instructions regarding our Solosec product, seek help on how to use our products, if you have drug safety questions, report an adverse event or provide us with any comments or concerns about our products, as further described in our Pharmacovigilance Privacy Statement.

Information We Automatically Collect Using Technology

In the past, we collected information about your computer or other electronic device when you visited our Website. This information may have included your Internet Protocol (IP) address, Internet Service Provider (ISP), domain name, browser type, operating system, location, website you visit before or after you visited this Website, pages you clicked on this Website, search requests, date and time of your requests, the amount of time spent on the Website and information provided by tracking technologies, such as cookies, single-pixel tags, local share, local storage, Etags, and scripts.

In the past we used cookies in conjunction with third parties to serve advertisements to your computer or other electronic device or to collect analytics information while you are using our Website.

We have now chosen to disable advertising and analytics cookies on our Website. We still maintain essential cookies and functional cookies on our Website. Essential cookies are required for a website to function properly and are necessary to enable basic features. Functional Cookies are cookies that aid in the functionality of a website. These cookies help enhance a website’s performance and functionality, by, among other things, remembering user credentials for automatic login or a user’s preferences. If you disable functional cookies, you may not be able to use the portions of our Website or the quality of your user experience may be impacted.

Information We Collect from Third-Party Sources

We, now or in the past, have collected Personal Information from health care professionals, public sources, and third-party sources.

4. WHAT ARE THE PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION?

We collect Personal Information for the following business or commercial purposes:

5. WHEN DO WE SHARE OR DISCLOSE PERSONAL INFORMATION?

Below, we explain (a) the purposes for which we share or disclose your Personal Information and (b) the entities with whom we disclose or share your Personal Information to provide services for us and (c) the third-party entities with which we “shared” your Personal Information to serve you with targeted advertising or related purposes. We conducted targeted advertising when we show you ads based on your Personal Information and the products we believe may interest you.

6. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

Personal Information about you will be accessible to Lupin, including its Affiliates, and to individuals and organizations that use Personal Information solely for and at our direction. Lupin may transfer your Personal Information to one of its databases outside your country of domicile.

Lupin uses reasonable security measures to protect your Personal Information. We use practices appropriate to the nature of the Personal Information to protect against the unauthorized or illegal access, destruction, use, modification, or disclosure of Personal Information.

Uses and disclosures of Personal Information by service providers acting on our behalf are governed by agreements that require Personal Information to be protected appropriately. Personal Information will only be used and disclosed by us and those working on our behalf, in a manner consistent with this Statement, other applicable privacy statements or notices, data, with accessed controlled as needed and as explicitly permitted or required by applicable laws, rules and regulations.

7. YOUR DATA PRIVACY CHOICES

We recognize that you may want to limit how your Personal Information is used and shared. We currently offer the following choices and options:

  • Updating your Personal Information: You may update your Personal Information by contacting us as described in Section 11 below.

8. ACCESS BY CHILDREN

Our Website is not directed at children and is designed for individuals who are 17 years of age or older. Where requests for information about a product are permitted by law, individuals requesting information about a product that is indicated for use by children must be 16 years of age or older. We do not knowingly collect Personal Information from children under 16 years of age, or according to local law, without obtaining verifiable parental consent prior to collection. If you are a parent or guardian that has knowledge that we have collected Personal Information from your child, please contact complianceandethicsoffice@lupin.com to request removal and we will endeavor to verify the identity of any applicable child Personal Information and make commercially reasonable attempts to delete such Personal Information.

9. SOCIAL MEDIA PLATFORMS

Lupin is active on Facebook®, Instagram®, X, previously known as Twitter, YouTube®, and LinkedIn ("Social Media") that enable online sharing and collaboration among customers. Anything you post on Social Media is public information and will not be treated confidentially. Lupin may post (or re-post) on the Website and our Social Media pages any comments or content that you post on our Social Media pages.

10. ACCESS FROM OUTSIDE THE UNITED STATES

The Website is intended for consumers within the United States. If you access our Website from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by other jurisdictions.

11. CONTACT US

We seek to constantly improve how we manage the collection and use of Personal Information. If you have questions regarding this Privacy Statement or how we treat your Personal Information, please contact us using any of the methods listed below.

By contacting us, you understand that you may share, and we may collect your health information as part of your communication with us.

12. ADDITIONAL TERMS APPLICABLE TO CALIFORNIA, TEXAS, AND CONNECTICUT RESIDENTS ONLY - YOUR PRIVACY RIGHTS

This section provides additional terms that apply to residents of California, Texas, and Connecticut. In the event of a conflict between this Section and the remainder of this Privacy Statement (“Statement”), this Section shall take precedence for California, Texas, and Connecticut residents. In this section only, any capitalized terms not defined in this Statement have the meanings set forth in the California Consumer Privacy Act of 2018 and its implementing regulations as amended (the “CCPA”) or the Connecticut Data Privacy Act ("CTDPA"), or the Texas Data Privacy and Security Act ("TDPSA").

Your Privacy Rights:

California and Texas residents have rights regarding the privacy of their Personal Information. Connecticut residents have privacy rights over their Consumer Health Data.

1. Right to Opt Out of the Selling or Sharing of Your Personal Information

California residents have the right to opt out of the “Selling” or “Sharing” of their Personal Information as defined in the CCPA. Connecticut and Texas residents may direct us to cease processing their Personal Data for targeted advertising, selling their Personal Data, or profiling in furtherance of decisions that produce legal or similarly significant effects. As of the date of the posting of this Privacy Statement, we do not conduct any of these activities.

2. Right to Revoke Consent

If you are a Connecticut resident, you may be able to revoke consent to the processing of your Consumer Health Data you share with us, subject to certain exceptions permitted by applicable law.

3. Right to Access

California residents have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of Personal Information we collected from you, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting your Personal Information, (d) the categories of third parties with whom we shared your Personal Information, and (e) the specific pieces of Personal Information we collected from you.

Connecticut and Texas residents have the right to confirm whether we are processing your Personal Information and to access that information.

4. Right to Request Deletion

Depending on the state in which you live, you have the right to request that we delete Personal Information we collected from you or the right to request that we delete all Personal Information we have collected about you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.

5. Right to Correct Your Information

You have a right to request that we correct your inaccurate Personal Information. If you request that we correct inaccurate Personal Information about you, we will use commercially reasonable efforts to correct it. If necessary, we may ask that you provide documentation showing that the information we retained is inaccurate.

6. Right to Data Portability

You may request a copy of the Personal Information you previously provided to us in a portable and, to the extent technically feasible, readily usable format.

How to Exercise Your Privacy Rights. To exercise your privacy rights described in this Section, you may submit your request to us by contacting us at any of the following:

By contacting us, you understand that you may share, and we may collect your health information as part of your communication with us.

Verifiable Consumer Request. In order to verify your request to exercise your rights, except for the right to opt out, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information. You must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.

When we receive your request to exercise your rights: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, and the likelihood of fraud.

We will only use the Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

When We Will Respond. We will try to respond to your request to exercise your privacy rights within 45 days. If we require additional time, we will inform you of the reason and extension period. For data portability requests, we will select a format to provide you with that Personal Information. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. A parent or legal guardian may make a request on behalf of his or her child.

Connecticut and Texas residents may submit a request to opt out through an authorized agent. California residents also have the right to submit requests to exercise any privacy right through an authorized agent. You may designate an authorized agent to make a request on your behalf to exercise your rights by doing the following: (1) provide the authorized agent written permission to do so; and (2) verify your own identity (per the process stated above), as well as the identity of the authorized agent directly. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf. We will not require authorized agents to verify your identity to effectuate an opt-out request. We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.

Right to Non-Discrimination. You have the right to not receive discriminatory treatment for exercising any of your privacy.

Additional Terms for California Residents

  • Categories of Personal Information We Have Collected. During the past 12 months, we have collected the following categories of Personal Information: Identifiers, Activity, Sensory Data, Protected Classifications, and Inferences.
  • Categories Of Personal Information Disclosed for A Business Purpose. During the past 12 months, we have disclosed the following categories of Personal Information for a Business Purpose: Identifiers, Protected Classifications, Internet Activity, Sensory Data, and Inferences to the Sources described in this Statement.
  • Sharing Personal Information. In the last 12 months we have not Sold your Personal Information to a third party for monetary compensation. We have Shared Personal Information with third parties for the purposes of serving targeted advertising, including: Identifiers, and Internet Activity to the Sources described in this Statement. As of the date of this Privacy Statement, we no longer Share your Personal Information.
  • We Do Not Use or Disclose Sensitive Information. We do not use or disclose Sensitive Information.

Shine the Light. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to complianceandethicsoffice@lupin.com or write to us at: Lupin Inc., 400 Campus Dr, Somerset, NJ 08873.

APPEAL PROCESS FOR CONNECTICUT AND TEXAS RESIDENTS

Right to Seek and Appeal. If you disagree with our refusal to take action on your request to exercise your privacy rights, you have the right to ask us to reconsider. You must submit your request within 60 days of your receipt of our denial. You may submit your request to us by:

By contacting us, you understand that you may share, and we may collect your health information as part of your communication with us.

Appeal Timeframe. Once we receive your request, we will acknowledge and start processing your request. Within 60 days of receiving your request, we will inform you in writing of any action taken or not taken in response to your request, including a written explanation of the reasons for our decision.

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Privacy Policy

LUPIN'S PLEDGE ON PRIVACY ("PLEDGE")

You care about the protection of your Personal Data – so do we. At Lupin Inc. ("Lupin"), we endeavor to ensure and maintain the privacy and data security of all Personal Data collected or retrieved by your use, as a visitor, of our websites. The term "Personal Data" as used throughout this Pledge refers to any information by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identified by which you may be contacted, identified, located or tracked.

This Pledge applies to Personal Data collected by or on behalf of Lupin and its service providers through this website, online resources and communications. This Pledge does not apply to Personal Data collected from offline resources and communications, except in cases where such Personal Data is consolidated with Personal Data that we, or others on our behalf, collect online. This Pledge also does not apply to third-party online resources to which our websites may link, where we do not control the content or the privacy practices of such resources.

Our Pledge complies with internationally recognized standards of privacy protection. Please read this Pledge carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Contact). 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. Should you have any questions about this Pledge or our Personal Data practices, please contact us at ComplianceOffice@Lupin.com.

CATEGORIES OF PERSONAL DATA

As most of our website content is informational and does not require account creation or registration, individuals may access many parts of our websites and online resources without disclosing any Personal Data. However, where we do collect Personal Data, we do so online through websites and other online resources. We also offer online resources in collaboration with other online service providers, from which we may receive Personal Data about users of such resources. These online collaborations are governed by agreements that require Personal Data to be protected appropriately. There are three methods that we use to collect Personal Data on our Website:

1. Information that you provide: We collect Personal Data and other data that you or your household may enter into forms or data fields on our websites or online resources. Such information may include, but not be limited to, contact information (such as your name, postal address, e-mail address, telephone number), date of birth, professional credentials, experiences, activities, skills, preferences, hobbies and interests. We may also collect, when relevant for the processing purpose, health information about you that you provide by responding to our questions and surveys or through your use of online and downloadable health-related tools we provide.

2. Information from public or third party sources: We may collect Personal Data about health care professionals who register on our websites from public or third-party sources to verify their professional credentials and identity. We may also collect Personal Data about you from third parties and public internet source via what is known as social media listening, examples including social networking, communities, forums, message boards, blogging. We may combine that data with Personal Data or other data we collect. This enhances our existing data about our users (e.g., adding address data), improves our ability to contact you, and enhances our marketing capabilities.

3. Information collected from your computer or other electronic device: We collect information about your computer or other electronic device when you visit our websites and use our online resources. This information may include your Internet Protocol (IP) address, Internet Service Provider (ISP), domain name, browser type, operating system, location, websites you visit before or after you visit this website, pages you click on this website, search requests, date and time of your requests, the amount of time spent on the website and information provided by tracking technologies, such as cookies, singlepixel tags, local share objects (Flash), local storage, Etags and scripts. If you leave one of our websites without becoming a registered user, we may use cookies in conjunction with third parties to service advertisements to your computer or other electronic device to remind you about our website that you had previously visited. Please reference our Cookie Policy Section for more information about cookies and how you can control them. If you use a mobile device to access our websites and online resources, we may also collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile websites and other mobile resources.

We may use other companies to deliver email communications on our behalf or to place our advertisements on other websites. Please review the privacy policies of these third parties to familiarize yourself with their practices.

INTENDED USE OF PERSONAL DATA

We may use all categories of Personal Data listed above for the following business purposes:

As Stated or Agreed to at the Point of Collection. We may use Personal Data for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.

Administration. We use Personal Data for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, to understand the Site's demographics and user preferences, for evaluating applications, and managing profiles. We also may use Personal Data to audit our online resources for compliance, authorized access and security.

Site Management. We use Personal Data for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site to you and our users.

Advertising/Marketing. We may use Personal Data to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our website, to notify you of changes to our Terms or this Policy, and for other similar communications. Social medial listening is the process by which we identify and assess what is being said about a company, individual, product or brand on the Internet. We will only collect relevant, adequate and not excessive publicly available Personal Data. Because of the nature of Social Media, it may not be possible for us to identify the individual who posted the original content that we collect. If Personal Data is collected and will be processed beyond the original intent when you posted the content, reasonable efforts will be made to provide notice to you as soon as is practical. Note, in some cases, it may not be possible to collect and verify your contact details given the available information. Reasonable efforts might entail identifying your contact details from the social media platform, if possible, or within the posting. Moreover, we will make reasonable efforts to provide you with a mechanism by which to opt-out of our data processing or exercise your rights as required by our policy and applicable regulations.

To Protect Our Rights. We may use Personal Data to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.

Consistent with the purposes identified and standards set within this Pledge and other applicable privacy notices that have been provided, in some cases we consolidate and use Personal Data that individuals share with us through various services and channels, such as the telephone, surveys, websites and other online resources and communications, in order to enhance the quality of services that we offer.

STATEMENT ON CHILDREN

In general, our websites and online resources are not directed at children and most of the online services that we offer are designed for individuals who are 18 years of age or older. Where requests for information about a medication are permitted by law, individuals requesting information about a medication that is indicated for use in children must be 18 years or age or older.

We do not knowingly collect Personal Data from children under 13 years of age, or according to local law, without obtaining verifiable parental consent prior to collection. If you are a parent or guardian that has knowledge that we have collected information from your child, please contact ComplianceOffice@Lupin.com to request removal and we will endeavor to verify the identity of any applicable child Personal Data and make commercially reasonable attempts to delete such Personal Data.

YOUR CHOICES

You may choose not to provide any Personal Data to us online by electing not to enter any Personal Data into a form or data field on our websites, and by not using any personalized services provided by our online resources. However, some of our online resources require users to identify themselves in order to use personalized services or advanced features, which will not be available without such data.

Some of our websites may request your permission to use and disclose Personal Data about you in order to add you to our contact lists, to enable you to list yourself in a directory or social media resources, and to identify and offer additional services and promotions that we believe you might find interesting. You can limit the use of Personal Data about you by checking or un-checking options provided at the time that you enter that information or that we may offer to you in the future. Additionally, you may change your communications preferences (such as to opt-out of communications you requested previously) by using the opt-out link provided in our electronic communications or by contacting us at ComplianceOffice@Lupin.com.

Our online resources that use tracking technologies, such as cookies, to remember your personal preferences and selections, enable you to choose whether you want us to use such technologies to remember you, or to provide additional services to you, by checking or un-checking options provided during registration, or at the time that you enter Personal Data inform forms or data fields. If you leave one of our websites without becoming a registered user, we may use cookies in conjunction with third parties to service advertisements to your computer or other electronic device to remind you about our website that you had previously visited. Our online resources do not limit non-identifiable uses of tracking technologies for individual users. Individual users can control the use of certain tracking technologies, such as cookies, through most Internet browsers. Some Internet browsers enable you to limit or disable the use of cookies for individual websites. Other browsers allow you to select cookie settings for all websites that you visit. If you are concerned about the use of cookie technology, please see our Cookie Policy section for more information about cookies and how you can control them. If you would like to exercise your choice of tracking for advertisement purposes, you can use the pop-up banner on Company websites where available.

You may choose to receive optional marketing email and other communications from us by signing up for or subscribing to these communications on our websites and other online resources. If you do not wish to receive optional email communications, you may opt-out by visiting the website or other online resources where you subscribed, where available, and update your email communication selections, or you may follow the unsubscribe or opt-out instructions in the email communications you receive from us. You also may optout by contacting us at ComplianceOffice@Lupin.com. If you do not with for us to confirm where you have read certain email communications we have sent you, you may opt of of email communications tracking by opting out of receiving those email communications altogether.

NON-DISCLOSURE OF INFORMATION

Personal Data about you will be accessible to Lupin, including its subsidiaries, divisions and groups worldwide, and to individuals and organizations that use Personal Data solely for and at the direction of us. Lupin may transfer your data to one of its databases outside your country of domicile. We will ensure that such data transfers are adequately protected.

Uses and disclosures of Personal Data by external individuals and organizations acting on our behalf are governed by agreements that require Personal Data to be protected appropriately. Personal Data about you will only be used and disclosed by us and individuals and organizations working on our behalf, in a manner consistent with this Pledge, other applicable privacy notices, data, with accessed controlled as needed and as explicitly permitted or required by applicable laws, rules and regulations.

Lupin will not sell, share, or otherwise distribute your Personal Data to third parties except as described in this Pledge and other applicable privacy notices. However, circumstances may arise where we may, for business reasons, decide to reorganize or divest our business through sale, merger or acquisition. In these circumstances, Personal Data may be shared with actual or prospective purchasers. We will obtain written assurances that Personal Data will be protected appropriately in these circumstances.

We reserve the right to disclose Personal Data about you for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required of explicitly authorized by applicable law. Otherwise, Personal Data about you will not be shared without your permission.

YOUR RIGHTS: ACCESS, CORRECT & DELETE

Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, you may exercise the following rights with regard to your Personal Data.

To gain access to Personal Data about you collected online, and to keep it accurate, complete and current, or to request deletion, you may contact us at ComplianceOffice@Lupin.com. In some cases, where we are required to retain information by law or regulation, or to continue to manage a service you have requested, or to ensure that we honor your preferences, or for other necessary business purposes, we may not be able to delete certain Personal Data about you. Where offered, you also may update Personal Data about your online by modifying information that you previously have entered into forms or data fields on our websites. Where permitted by law, our ability to access and correct Personal Data will be limited where access and correction would: inhibit our ability to comply with a legal or ethical obligation, inhibit our ability to investigate, make or defend legal claims, result in disclosure of Personal Data about a third party, result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to us or a third party.

COOKIE POLICY

Lupin Inc. ("Lupin") uses cookies to improve the experience for visitors to our Websites, including Websites that can be accessed through our mobile applications. This Cookie Policy ("Policy") supports Lupin's Pledge on Privacy ("Pledge") by providing more detail about the types of cookies and similar technologies that our Websites, web applications and other online services use (collectively, "Websites") and how you can control cookies on your computer or mobile device.

Cookies & Other Tracking Technologies.

What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively "Cookies") on our Website.

What are cookies and web beacons / pixel tags? A cookie is a small text file that our Website saves onto your computer or device when you use the Website that provides us certain information about your activities. Cookies allow the Website to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

Why do we collect Cookies? We use Cookies to:

· make our Website function properly;

· provide personalized experiences;

· tailor our interactions with you;

· help with our marketing efforts;

· provide us with valuable data and statistics about the usage and effectiveness of our Website and to help us improve our Website; and

· help us improve our services.

What type of information do Cookies collect? The Cookies on our Website may collect information such as:

· IP addresses assigned to the computers and other devices you use;

· your internet service provider;

· device ID number;

· approximate geographic location;

· browser type;

· Website pages visited;

· Websites you access before and after visiting the Website, and

· data related to how and when you use the Website.

We may combine information from Cookies with Personal Data, including data obtained from third parties.

How long do Cookies last? A Cookie can either be a "session" Cookie or a "persistent" Cookie. Session Cookies exist only for so long as you are visiting the applicable Website and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a Website that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

Flash cookies differ from other browser cookies regarding the amount and types of data collected and how the data is stored. Your browser will not remove and cannot manage Flash cookies in the same way as other Cookies. To learn about managing your Flash cookie settings, visit the Flash player settings page on Adobe's Website.

We are not responsible for third-party Cookies. Cookies may either be "first-party" or "third-party" Cookies. A first-party Cookie allows your web browser to talk to the actual Website that you are visiting (i.e. this Website). A third-party Cookie allows your web browser to talk to a third-party Website, such as the source of an ad that appears on the Website you are visiting or a third-party analytics provider. We do not have control over third-party Cookies. Third-party Cookies are not governed by this Policy.

How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Website. Not all features or functions of the Website may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Website.

Analytics. We use Google Analytics or similar services to collect and process information about your use of the Site. The service providers set cookies and then your web browser will automatically send data. The service providers uses this data to provide us with reports that we use to improve the Website's structure and content. We may implement additional add-on services to Analytics, such as Demographics and Interest Reporting. Demographics and Interest Reporting uses Cookies to collect data about our Website traffic by tracking users across Websites and across time to provide us with analytics on our user base.

Online Behavioral Advertising. We use third parties to provide internet-based advertising services. These services collect data about your interactions with the Site and other Websites to send you targeted advertisements for goods and services. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other Websites and may be sent to you via email.

We use Google Ads or equivalent service providers to serve ads across various Websites. These service providers use Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other Websites that you visit. To opt-out of this type of advertising, to customize your ad preferences, or to limit the collection or use of such data, visit their settings page and follow their personalization and opt-out instructions. Opting out will not affect your use of the Site.

To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to ComplianceOffice@Lupin.com or write to us at: 5801 Pelican Bay Boulevard, Suite 500, Naples, Florida 34108.

SECURITY AND CONFIDENTIALITY

We use commercially reasonable technical and organizational measures to help secure Personal Data against loss, misuse, and alteration appropriate to the type of Personal Data processed. If a breach of your Personal Data occurs, we will notify you of the breach if required under applicable law.

YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL DATA, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND YOU PROVIDE PERSONAL DATA AT YOUR OWN RISK.

RECORD RETENTION

We generally retain Personal Data for only as long as reasonably needed for the specific business purpose or purposes for which it was collected and the duration of your use of our websites. In some cases, we may be required to retain information for a longer period of time based on laws or regulations that apply to our business, such as applicable rules on statute of limitations or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the original retention period.

LINKS TO OTHER SITES

This Website Privacy Pledge applies only to Lupin's websites. The Site may link to, or be linked to, websites not owned or controlled by us. We are not responsible for third-parties' privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

CONTACT

We aim to constantly improve the tools available to you to manage the data that you provide to us. We may update this policy periodically. We reserve the right to modify, add or remove portions of this Website Privacy Pledge at our discretion. If we decide to change this Pledge, we will post those changes at this site on our homepage so you always will know what information we gather, how we might use that information, and whether we will disclose it to anyone. Please refer to this page from time to time to review these and other new features or updates. This policy was last updated on May 4, 2020.

Terms of Use

Terms of Use

Please carefully read these Terms of Use and our Privacy Policy before using our Website. By using the Lupin Website, you agree to follow and be bound by these Terms of Use and our Privacy Policy without modification. In the case of any violation of these Terms of Use, Lupin reserves the right to seek all remedies available at law and in equity for such violation. Because we will continue to implement new technologies and improve the services and features we provide on our Website, this statement is subject to change without prior notice. For that reason, we encourage you to review this statement periodically. By using our Website, you agree to the Terms of Use in effect at that time.

Use of Website

The Lupin Website may contain other proprietary notices and copyright information, the terms of which must be observed and followed. Information on this Website may contain technical inaccuracies or typographical errors. Information may be changed or updated without notice. Lupin reserves the right to refuse service in its discretion, including, without limitation, if Lupin believes that customer conduct violates applicable law or is harmful to the interests of Lupin.

Submitted Information

No information or material provided to Lupin by you through our Website may contain vulgar, obscene, threatening or otherwise unlawful language or material. Lupin will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless we obtain your permission to use your name or we are required to do so by law. Please review our Privacy Policy for a complete description of how we handle personal information submitted to us. Lupin Information Lupin has made a conscious effort to display and describe information about Lupin on the site accurately so that you can get a good idea of our business. Furthermore, Lupin is constantly improving its information. The materials on this Website are for your general educational information only. Lupin does not practice medicine or provide medical services or advice, and the information on this Website should not be considered medical advice. You should always rely on your health care professional for diagnosis and treatment.

Trademarks

Lupin's names and logos referenced on the Website are trademarks of Lupin in India and other countries and may not be used in connection with any product or service in any manner that is likely to cause confusion among customers or in any manner that disparages or discredits Lupin.

All other trademarks not owned by Lupin that appear on this Website are the property of their respective owners, who may or may not be affiliated with, connected to, or sponsored by Lupin. If you use the materials or trademarks on this Website in a way that is not clearly allowed by these Terms of Use, you are violating your agreement with us and may be violating copyright, trademark, and other laws. In that case, we automatically revoke your permission to use this Website. Title to the materials remains with us or with the authors of the materials contained on this Website. All rights not expressly granted are reserved.

Change to Term of Use

Lupin reserves the right to update the Terms of Use statement at any time. Any changes or updates will be effective immediately upon posting to this Website. Your use of this Website constitutes acceptance of our Terms of Use. If you do not agree to the terms, please exit from this Website immediately.

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