ImmunoGen, Inc. and its affiliates (“ImmunoGen”) are committed to protecting and respecting your privacy and continuing compliance with the evolving legal and regulatory standards for privacy and data protection applicable in the jurisdictions where it conducts its activities. This Privacy Statement (the “Privacy Statement”) is intended to let you know what information we may collect about you and how we use that information and includes details regarding appropriate cross-border data transfer mechanisms. Please read this Privacy Statement carefully to understand our practices regarding your personal information and how we will handle your personal information.
II. SCOPE OF THIS PRIVACY STATEMENT
This Privacy Statement represents ImmunoGen’s global privacy standards and applies to all Personal Information collected, processed, shared, or used by ImmunoGen in its various activities. ImmunoGen may revise this Privacy Statement by updating this posting. Personal Information will be handled in accordance with the policy in effect at the time it is collected.
“Personal Information” means all information that relates to an individual or information that can be used to identify a person, both directly (e.g., your name or your photograph) and indirectly (e.g., a medical insurance number, your position in a company, or a study code assigned to you in a clinical trial). In some countries, Personal Information may also include information such as medical device serial numbers, biological samples, internet protocol addresses, or information relating to a company.
ImmunoGen processes the following types of Personal Information for the purposes indicated:
Patient Personal Information. ImmunoGen collects and processes Personal Information of patients participating in its patient support programs, including to provide access support, co-pay assistance services, and patient financial assistance services, as well as to provide educational materials, and conduct surveys, data analytics, market research and other internal business activities related to the patient support programs and ImmunoGen products and programs. ImmunoGen may communicate with patients participating in patient support programs via email, phone or text messaging. If a patient opts in to text messaging communications with ImmunoGen, ImmunoGen will not share such patient’s mobile contact information with third parties for marketing and promotional services. For patients that participate in ImmunoGen sponsored clinical trials, patient names and other direct identifiers are not attached to records or samples collected by ImmunoGen; such records and samples are only identified by a code.
Healthcare Professional Personal Information. ImmunoGen analyzes the professional profiles of doctors and other healthcare providers for the purpose of identifying potential investigators to assist in clinical research or otherwise collaborate with ImmunoGen.
Employee Personal Information. ImmunoGen collects and processes its employees’ Personal Information to ensure compliance with employment agreements. ImmunoGen also processes the Personal Information of job applicants, and to a certain extent, ex-employees.
Vendor Personal Information. ImmunoGen interacts with various third parties and records certain Personal Information of their staff to be able to conduct activities together and for the performance of any vendor-related contracts.
Web Visitors Data. ImmunoGen collects Personal Information about visitors to company websites through the voluntary provision of the information by the data subject, e.g., where a data subject applies via the website for employment with ImmunoGen. Through the use of cookie-based technologies, ImmunoGen may collect various data linked to virtual identities assigned to visitors when they access our websites. This data is used for various purposes, including site analytics and first-party marketing. In certain cases, these virtual identities are linked to the real-world identities of visitors when they provide their Personal Information. This allows ImmunoGen to tailor marketing messages to those individuals, inclusive of information that is likely to be of interest to them. Web visitors may visit ImmunoGen’s website without providing any Personal Information. If a web visitor chooses to contact ImmunoGen and provide Personal Information, ImmunoGen will use it for the purpose for which it has been submitted to ImmunoGen, e.g., to respond to a request for information or to apply for an open position with ImmunoGen. ImmunoGen may also use Personal Information provided by web visitors who are patients for marketing and promotional purposes.
If a web visitor does not wish to receive any email or other communication from ImmunoGen after requesting information, the web visitor may contact ImmunoGen at http://investor.immunogen.com/unsubscribe.
III. COLLECTION AND PROCESSING OF PERSONAL INFORMATION
ImmunoGen will seek consent from data subjects to collect, use, and disclose their data where mandated by data privacy law or where it is a matter of good practice. Specific requirements may vary by jurisdiction and ImmunoGen will always adhere to the relevant applicable requirements.
As required under applicable law, ImmunoGen shall:
We use Personal Information to:
ImmunoGen recognizes that responsible management of Personal Information is required to protect privacy rights and comply with data privacy laws and regulations. Personal Information may be shared with other ImmunoGen affiliates, government agencies, and third parties on a “need to know” basis for legitimate business reasons or as otherwise allowed or required by law.
As part of the life sciences industry that is increasingly globalized in its approach, ImmunoGen may share Personal Information across international borders where required to support global projects, particularly our global clinical trials. ImmunoGen hosts Personal Information in databases in different locations throughout the world, although mainly in the United States. ImmunoGen recognizes that many countries have regulations restricting the flow of Personal Information across international borders and has implemented measures to ensure that adequate protection applies to the international transfer of data where legally mandated.
When required by applicable law, ImmunoGen will ensure an appropriate and lawful response to data subjects who exercise their individual rights to (1) know what Personal Information is being processed, (2) object to processing, and/or (3) request correction, erasure, or blocking of their Personal Information.
ImmunoGen will take commercially reasonable and appropriate measures to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into consideration the risks involved in the processing and the nature of the Personal Information.
ImmunoGen does not collect information through our websites from individuals who are known to be designated as children under respective applicable data privacy laws, and no part of our online presence is directed to any minors.
Cookies are information packets sent by web servers to web browsers and store by the web browsers. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers. There are two main kinds of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, whereas persistent cookies remain stored on your computer until deleted or until they reach their expiry date. Persistent cookies can be used to collect identifying information about the user, such as Web surfing behavior or user preferences for a specific Web site. Our website uses the following cookies for the following purposes:
Google Analytics Cookies
Most browsers allow you to refuse to accept cookies.
In Internet Explorer, you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.
In Firefox, you can adjust your cookies settings by clicking “Tools”, “Options” and “Privacy”.
In Chrome, you can access cookie settings and opt to block cookies by clicking “Options”, “Under the Hood”, and toggling the settings in the “Cookies” section.
In Safari, cookies can be managed by clicking “Preferences”, “Security”, then toggling in the “Accept cookies” section. Blocking cookies will have a negative impact upon the usability of some websites.
For Firefox users, the add-on Lightbeam allows you to see which sites are storing cookies to track you. Chrome offers a “Keep My Opt-Outs,” a tool which allows users to permanently opt your browser out of online ad personalization via cookies.
V. Contact Information
All communications, queries, requests to exercise data subject rights (e.g., access to data), or complaints should be addressed to the attention of the ImmunoGen Data Protection Officer at Privacy@ImmunoGen.com.