PRIVACY POLICY

This Privacy Policy governs your (“You” or “Your”) use of this Website. Cosette Pharmaceuticals (“We”) has created this Privacy Policy to inform You about Cosette’s (“Cosette” or “We” or “Us”) privacy practices, including what information We collect (including information collected by this website (“Website”); how We use that information; and who We will share that information with, if at all. By visiting and/or using Cosette’s Website or otherwise providing Us with Your personal information, You are agreeing to the terms of this Privacy Policy and the Terms of Use available here Terms of Use. Please read this Privacy Policy carefully to help You make informed decisions about what information You provide to Cosette.

If You do not consent to the collection, use, and sharing of Your information as described in this Privacy Policy and Terms of Use, You should not use the Website or otherwise provide Us with personal information.

The Website is intended for a United States audience. Any information You provide, including any of Your personal information, will be transferred to, and processed, by a computer server located within the United States.

We may update this Privacy Policy at any time. Any modifications to this Privacy Policy are effective as of the date they are posted to the Website. Your continued use of the Website after any modifications constitutes Your acceptance of the modified Privacy Policy. You may access the most recent version of this Privacy Policy at any time through the link provided on the Website’s homepage.

1. INFORMATION WE COLLECT

What Information We Collect & Why We Collect It

Non-technical personal information

We  collect “personal information” that you provide to us or (potentially including Your name, address, email, and other information that may relate directly back to you) to provide You with customer support and otherwise communicate with You when You request information, interact with job postings, or otherwise directly or indirectly provide Us with Your personal information (for example Your interactions with Us and Cosette’s advertising).

We also collect “personal information” provided to us or (potentially including Your name, address, email, and other information that may relate directly back to you) in connection with any product inquiries, complaints, adverse events, or side effects that You experience using Cosette’s products.

Traffic Data, Cookies, and Similar Technology personal information

We may automatically collect or receive additional information regarding Your use of the Website, and information regarding the computer and mobile devices You use to access the Website (collectively, the “Traffic Data”).Traffic Data may include (a) Your IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; (b) login credentials and login tracking data; (c) information about Your mobile device including but not limited to network and carrier; (d) browser type and language; (e) any modifications made to Your account; (f) geolocation information; (g) referring and exit pages and URLs; (h) date and time of access to Cosette’s Websites; and () details regarding Your activity on the Website, such as search queries and other performance and usage data.

We may use cookies, pixel tags, and other similar technology to collect information about You and how You use the Website. Cookies are small text files the Website can use to recognize You as a repeat visitor and may include both session cookies, which expire once You close the Website, and persistent cookies, which stay on Your computer or mobile device until You delete them. Pixel tags recognize a browser’s cookie when a browser visits a particular Website on which the pixel tag is located in order to learn which advertisement brings You to a given Website. By using the Website, You consent to the processing of data about You by these analytics providers for the purposes set forth in this Privacy Policy.

We may use this type of technology for various purposes, including to: (a) identify Your computer or mobile device; (b) personalize Your experience; (c) utilize and provide features of social media platforms; (d) analyze which portions of the Website are visited and used most frequently; (e) enhance and improve the Website and Your experience using the Website; and (f) measure and optimize advertising and promotional effectiveness.

You can opt out of Cosette’s use of cookies by setting Your computer or mobile device to reject cookies. You can still use the Website if You choose to disable cookies, although Your ability to use some of the features may be affected.

You may use certain aspects of the Website, such as general browsing of content and information, anonymously. In these cases, We will only collect personal information that You voluntarily submit to us. Anonymous use of Cosette’s Website or failing to provide Us with personal information may limit or restrict Your ability to use this Website.

2. HOW INFORMATION IS USED AND SHARED

By using the Website, You authorize Us to share, disclose, and otherwise use Your information to: (a) create an account for You to use the Website; (b) provide and improve the Website; (c) market and promote Cosette’s products and services; (d) solicit Your feedback; (e); as We may, in good faith, believe is required by law (such as to comply with a subpoena or court order or to share with regulatory agencies concerning Cosette’s products); (f) communicate with Cosette’s parent companies, subsidiaries, joint ventures, or other companies under common control with us; (g) contact You regarding job postings; (h) provide You with news and alerts; (i) protect Your safety or the safety of others; (j) enforce Cosette’s Terms of Use; and(k)(l) transfer assets in the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, where the information is part of the transferred assets.

In an ongoing effort to better understand users of the Website, We may analyze certain aspects of Your information in anonymized and aggregate form so that it is no longer personal information. We may use this aggregated data to operate, maintain, manage, and improve the Website and/or to provide new and additional products and services.

We may also engage third-party companies and individuals to perform functions on Cosette’s behalf such as providing technical assistance, software development, website hosting, advertising services, customer service, marketing assistance, and administration of Cosette’s various products and services. These other companies and individuals will have access to Your information only as necessary to perform their functions and to the extent permitted by law.

Third Party Analytics

We may use third-party analytics services (e.g., Google Analytics) to evaluate Your use of the Website, compile reports on Your activity, analyze performance metrics, and collect and evaluate other information relating to the products and services marketed and promoted via the Website. We may also engage third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers to perform these services on Cosette’s behalf. Cookies and other technologies may be used to help analyze and provide Us with this analytical data.

3. HOW INFORMATION IS STORED

We will store Your information in compliance with applicable law and for as long as necessary to provide You with certain services, respond to any request or communication You send to us, or as otherwise may be necessary for Us to comply with any legal, regulatory, or contractual obligations We may have.

We take commercially reasonable steps in accordance with industry security standards to protect Your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These steps include physical security, network security, strict policies on storage, transmission, and use of personal data and written agreements with third parties depending on the nature of information and the circumstances under which it is used or stored. No security system is 100% secure. We cannot guarantee the security of Cosette’s databases or the databases of the third parties with whom We may share Your information; nor can We guarantee that the information You supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to Usis not secure, and You should therefore take special care in deciding what information You send to Us via e-mail.

4. NOTICE TO NON-U.S. RESIDENTS

We use third party vendors to host the Website. The Website and its servers are operated in the United States. However, information collected through the Website may be replicated and stored in other places for archival, disaster recovery, and back-up purposes. If You are located outside of the United States, please be aware that Your information, including Your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of Your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in Your jurisdiction. If You are located outside the United States and choose to use the Website, You hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

5. LINKS TO THIRD PARTY WEBSITES

You may find links to the websites and services of Cosette’s business partners, suppliers, advertisers, sponsors, licensors and other third parties on Cosette’s Website. This Privacy Policy does not govern Your use of these third party websites and services. We do not control the content or links that appear on these websites and We are not responsible for the practices employed by these third parties. You should review the terms and conditions of any third party websites and services before supplying any of Your information.

6. CHILDREN

The Website is not directed to children under the age of 16 and We will not knowingly collect personal information from any child under the age of 16 except where required to comply with FDA (and other) regulations with regard to the safety of Cosette’s products.

7. CONTACT US

If You have questions about this Privacy Policy, You can contact us via e-mail at customerservice@cosettepharma.com or via mail at the following address: 200 Crossing Boulevard, 4th Floor, Bridgewater, NJ 08807 Attn: Customer Service.

8. CALIFORNIA RESIDENTS

THIS PRIVACY NOTICE, EFFECTIVE OCTOBER 1, 2023, AS REQUIRED BY THE California Consumer Privacy Act of 2018 (“CCPA”) AS SUBSEQUENTLY AMENDED, SUPPLEMENTS THE ABOVE PRIVACY POLICY AND CONCERNS visitors, users, and others who reside in the State of California. (The following are addressed in the above privacy policy: HOW COSETTE PHARMACEUTICALS COLLECTS YOUR PERSONAL INFORMATION; USE OF YOUR PERSONAL INFORMATION; NON-DISCRIMINATION; CHANGES TO THIS POLICY)

TYPES OF PERSONAL INFORMATION COLLECTED BY COSETTE PHARMACEUTICALS BY CATEGORY

CCPA Category of Personal Information Collected by Cosette Pharmaceuticals in the last 12 months
i. Identifier Name, postal address, email address, phone number, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, and other similar identifiers in connection with product inquiries and/or complaints or optional newsletters

Name, postal address, email address, phone number, online identifier, Internet Protocol (IP) address, professional identification numbers, prescribing information, and other similar identifiers in connection with product outreach to healthcare providers
ii. Customer Records See Identifiers above solely in connection with product inquiries and/or complaints or newsletters (requiring customer sign-up)
iii. Protected classification characteristics under California or federal law. not collected
iv. Commercial not collected
v. Biometric not collected
vi. Internet or network activity. Information regarding a consumer’s interaction with Cosette’s websites, application, or advertisement, passwords and pins created to access Cosette’s websites
vii. Geolocation data Geographic location based on URL
viii. Sensory data. not collected
ix. Professional or employment-related information. NPI and other healthcare provider designations and identifiers, and/or specialties;
x. Non-public education information not collected
xi. Inferences Cosette Pharmaceuticals may make certain inferences from individual or combined pieces of Information above
Personal Information does not include: Personal information does not include: Publicly available information from government records; De-identified or aggregated consumer information; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

DISCLOSURES OF PERSONAL INFORMATION IN LAST 12 MONTHS

  • Cosette Pharmaceuticals only discloses Your personal information as required by law or for a business purpose to Cosette affiliates, service providers and third parties where You or Your agent(s) have authorized that disclosure.
  • Cosette Pharmaceuticals does not collect information from minors. Cosette Pharmaceutical may come into possession of information of minors in connection with product inquiries, complaints, and/or adverse events whereby Cosette Pharmaceuticals complies with all FDA and other applicable regulations.
  • Cosette Pharmaceuticals does not sell any information referenced above.
  • In the preceding twelve (12) months, Cosette Pharmaceuticals has not sold any information referenced above.
  • In the preceding twelve (12) months, Cosette Pharmaceuticals has not disclosed any personal information in connection with a business purpose.

YOUR RIGHTS UNDER THE CCPA

CCPA ACCESS RIGHTS

You have the right to request that Cosette Pharmaceuticals disclose certain information to You about Cosette’s collection and use of Your Personal Information over the past 12 months. Once Cosette Pharmaceuticals receives and confirms Your verifiable consumer request, Cosette Pharmaceuticals will disclose to You:

  • The categories of Personal Information that Cosette Pharmaceuticals collected about You.
  • The categories of sources for the Personal Information that Cosette Pharmaceuticals collected about You.
  • Cosette Pharmaceuticals’ business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom Cosette Pharmaceuticals shared that Personal Information.
  • The specific pieces of Personal Information Cosette Pharmaceuticals collected about You (also called a data portability request).
  • If Cosette Pharmaceuticals disclosed Your Personal Information for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

CCPA DELETION RIGHTS

You have the right to request that Cosette Pharmaceuticals delete Your Personal Information, subject to certain exceptions. Once Cosette Pharmaceuticals receives and confirms Your verifiable consumer request, We will delete (and direct Cosette’s service providers to delete) Your Personal Information from Cosette’s records, unless an exception applies. Cosette Pharmaceuticals may deny Your deletion request if retaining the information is necessary for Us or Cosette’s service provider(s) to:

  • Complete the transaction for which Cosette Pharmaceuticals collected the Personal Information, provide a good or service that You requested, take actions reasonably anticipated within the context of Cosette’s ongoing business relationship with You, or otherwise perform Cosette’s contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise a right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • 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.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
  • Comply with a legal obligation such as retaining records in connection with complaints and/or adverse events for the statutory required period(s).
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

CCPA PORTABILITY RIGHTS

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by contacting Us at via email at customerservice@cosettepharma.com or mail Us at the following address: 200 Crossing Boulevard, 4th Floor, Bridgewater, NJ 08807, Attn: Customer Service; You may also reach us at 1-800-922-1038

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 Cosette Pharmaceuticals to reasonably verify You are the person about whom Cosette Pharmaceuticals collected Personal Information or an authorized representative.
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

Cosette Pharmaceuticals cannot respond to Your request or provide You with Personal Information if Cosette Pharmaceuticals cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You.

Cosette Pharmaceuticals will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

CCPA REQUESTS, RESPONSES, AND TIMING

Cosette Pharmaceuticals will try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Cosette Pharmaceuticals requires more time, Cosette Pharmaceuticals will inform You of the reason and extension period in writing. Cosette Pharmaceuticals will deliver Cosette’s written response by mail or electronically, at Your option. Any disclosures Cosette Pharmaceuticals provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Cosette Pharmaceuticals provides will also explain the reasons Cosette Pharmaceuticals cannot comply with a request, if applicable. For data portability requests, Cosette Pharmaceuticals 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. Cosette Pharmaceuticals does not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Cosette Pharmaceuticals determines that the request warrants a fee, Cosette Pharmaceuticals will tell You why Cosette Pharmaceuticals made that decision and provide You with a cost estimate before completing Your request.

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Us may choose to opt out of Cosette’s sharing their contact information with third parties for direct marketing purposes. If You are a California resident and You wish to opt out, please send an e-mail to customerservice@cosettepharma.com or call us at 1-800-922-1038.