Effective: April 2017

Your privacy is important to us, and it is Churchill Pharmaceuticals LLCs’ policy to respect your privacy regarding any information we may collect while operating our website at www.churchillpharma.com (the “Website”). This Privacy Policy discloses how we collect, use, communicate, disclose and make use of personal information of Website visitors (“Visitors”) and applies solely to the information that we collect through the Website. This Privacy Policy does not address personal information that you provide to us in other contexts (e.g., through a business relationship not handled through the Website).

• Acceptance of Privacy Policy

  By using the Website, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Website. Your continued use of the Website following the posting of changes to these terms will mean that you accept those changes.

• Personal Information Provided by You

  Churchill Pharmaceuticals collects your personally identifiable information (“PII”) through the Website when you choose to provide such information, such as when you submit information through the “Contact” page of the Website. This page requires you to provide your first and last names, and your email address. PII can include your name and email address.

• Use and Disclosure of Personal Information

  Churchill Pharmaceuticals will use your PII only to operate the Website or address your requests for information, products or services. Churchill Pharmaceuticals will not sell, rent, license or trade your PII with third parties for their own direct marketing use unless we receive your express consent to do so. Unless you give us permission to do so, Churchill Pharmaceuticals will not share your PII other than as specified in this Privacy Policy.

  Disclosures to Third Parties Assisting In Our Operations. Churchill Pharmaceuticals may share your PII under confidentiality agreements with other companies that work with, or on behalf of, Churchill Pharmaceuticals to provide products and services, such as a cloud hosting service or a document storage company. These companies may use your PII to assist Churchill Pharmaceuticals in its operations. However, these companies do not have any independent right to share this information.

  Disclosures Under Special Circumstances. We may provide information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

  Business Transfers. We may share your PII with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Churchill Pharmaceuticals’ business to such business entity. We will require any such successor business entity to honor the terms of this Privacy Policy.

• Automatically Collected Information and Anonymous Information

  Each time a visitor comes to a Website, Churchill Pharmaceuticals collects some information to improve the overall quality of the visitor’s online experience.

  Aggregated Data. Churchill Pharmaceuticals collects aggregate queries for internal reporting and also counts, tracks and aggregates the visitor’s activity into Churchill Pharmaceuticals’ analysis of general traffic flow at the Website. To these ends, Churchill Pharmaceuticals may merge information about you into aggregated group data. In some cases, Churchill Pharmaceuticals may remove personal identifiers from PII and maintain it in aggregate form that may later be combined with other information to generate anonymous aggregated statistical information. Such anonymous group data may be shared on an aggregated basis with Churchill Pharmaceuticals’ affiliates, business partners, service providers and/or vendors; if it does so, Churchill Pharmaceuticals will not disclose your individual identity.

  Web Server Logs and IP Addresses. An Internet Protocol (“IP”) address is a number that automatically identifies the computer or device you have used to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. Churchill Pharmaceuticals may use IP addresses to conduct Website analyses and performance reviews and to administer the Website.

  Cookies and Web Beacons. Cookies are pieces of information that a website transfers to a user’s computer for purposes of storing information about a user’s preferences. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Many websites use cookies as a standard practice to provide useful features when a user visits the website and most web browsers are set up to accept cookies. Churchill Pharmaceuticals uses cookies to improve your online experience when visiting the Website. You can set your browser to refuse cookies, but some portions of a Website may not work properly if you refuse cookies. Some of the Website’s web pages may use web beacons in conjunction with cookies to compile aggregate statistics about Website usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to maximize web traffic flow and to otherwise analyze the effectiveness of the Website. Some web beacons may be unusable if you elect to reject their associated cookies.

• Referrals/Links

  The Website may contain links to third-party websites that may offer information of interest. This Privacy Policy does not apply to those websites, and Churchill Pharmaceuticals recommends reviewing those websites’ privacy policies individually.

• Security

  Churchill Pharmaceuticals understands that storing our data in a secure manner is essential. Churchill Pharmaceuticals stores PII and other data using reasonable and appropriate physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. Please note, however, that while Churchill Pharmaceuticals has endeavored to create a secure and reliable website for Visitors, the confidentiality of any communication or material transmitted to/from the Website or via e-mail cannot be guaranteed.

• Response to “Do Not Track” Signals

  Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Churchill Pharmaceuticals does not process or respond to “Do Not Track” signals.

• Children’s Privacy Protection

  Under Age 13

  Churchill Pharmaceuticals understands the importance of protecting children’s privacy in the interactive online world. The Website is not designed for, or intentionally targeted at, children under 13 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any PII to Churchill Pharmaceuticals or the Website.

  Under Age 18

  Minors under 18 years of age may have the PII that they have provided to Churchill Pharmaceuticals through the Website deleted by sending a deletion request to Churchill Pharmaceuticals LLC, 3602 Horizon Drive, Suite 160, King of Prussia, Pennsylvania 19406, or calling 610-382-5610. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

• Changes

  You may review and request changes to your PII that Churchill Pharmaceuticals has collected, including the removal of your PII from Churchill Pharmaceuticals’ databases, in order to prevent receipt of future communications. You can mail your request to Churchill Pharmaceuticals LLC, 3602 Horizon Drive, Suite 160, King of Prussia, Pennsylvania 19406 or call 610-382-5610.

• Policy Updates

  This Privacy Policy may be revised from time to time as we add new features and services, as laws change and as industry privacy and security best practices evolve. We display an effective date on the policy in the upper right corner of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any change to this Privacy Policy regarding use or disclosure of PII, we will provide advance notice on the Website. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.

• Questions?

  If you have any questions about this Privacy Policy or about Churchill Pharmaceuticals LLC’s handling of your information, please contact us at Churchill Pharmaceuticals LLC, 3602 Horizon Drive, Suite 160, King of Prussia, Pennsylvania 19406, or call 610-382-5610.