CALIFORNIA PRIVACY POLICY

We are committed to protecting your privacy.

Overview

Travere Therapeutics, Inc., and its subsidiaries and affiliates (collectively “Travere Therapeutics,” ”we,” “our,” or “us”) are committed to respecting your privacy.  Travere Therapeutics’ California Privacy Policy (“Policy”) applies to “Consumers” as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), and is a supplement to Travere Therapeutics’ other privacy policies or notices.  In the event of a conflict between any other Travere Therapeutics policy, statement or notice and this Policy, this Policy will prevail for California Consumers and their rights under the CCPA.  Please also see our general privacy policy posted or referenced on our websites. Travere Therapeutics also has specific policies for how we process personal data from our website (cookies), for clinical trials and personal data for our employees.

This Policy covers the collection, use, disclosure, and sale of California Consumers’ “Personal Information” as defined by the CCPA (“personal data”).  This Policy also covers rights California Consumers have under the CCPA. Our data practices may change, and if our practices become materially different, we will provide notice as applicable in connection with the collection, including references to other applicable privacy policies and notices.

 

Types of personal data we collect and use

The personal data we may collect and process will depend on the nature of our interactions with Consumers, but can including the following categories of personal data we collect from the following sources and for the following purposes:

 

Categories of Personal Data Collected Categories of Sources Purpose for Collecting/Processing Categories of Third Parties to Whom We Disclose Personal Data
Identifiers – such as full name, postal address, online identifier, email address, previous residence address, phone numbers, date of birth, insurance policy information, unique personal identifier, or other similar identifiers.
  • You (directly from participant).
  • Health Care Practitioners through website or online submissions information requests.
  • Consumers website browsing sessions.
  • From our Service or Business Partners.
  • Distributors for product distribution.
  • Consumers and Health Care Practitioners for patient services and customer relationship management.
  • Directly from a clinical trial through the participation in clinical trials.
  • To provide you more information on a clinical trial or research.
  • To provide you investor information or compensation.
  • To provide you educational and marketing information about our own commercial and pipeline products and related disease states.
  • For patient related services including prescription fulfillment, reimbursement, insurance assistance and patient lab testing.
  • For customer support and relationship management including product distribution.
  • To set your website preferences through your online activity gathered through our weblogs and cookies.
  • To respond to your inquiries and to fulfil your requests.
  • To conduct clinical trials and research including providing information to clinics, research institutions, clinical research organizations, and healthcare professionals that we engage with for clinical trials.
  • To process job applicants and consideration of employment including working with third party background check provider to conduct necessary background checks.
  • To conduct relevant day to day business operations and adhere to applicable laws and regulations.
  • To comply with our contractual obligations.

 

  • Service Providers.
  • Contractors.
  • Distributors.
  • Manufacturers.
  • External Agencies.
  • External Auditors and Regulators.
  • Public Authorities / Government as required.
  • Share: Third party cookie providers and ad partners
Protected Characteristics – including but not limited to age, race or ethnicity, gender, disability, or specific conditions.
  • You (directly from participant).
  • Health Care Practitioners and Service Providers for patient services and customer relationship management.
  • Clinical trial participants.
  • To provide you more information on a clinical trial or research.
  • For patient related services including prescription fulfillment, reimbursement, insurance assistance and patient lab testing.
  • For customer support and relationship management including product distribution.
  • To conduct clinical trials and research including providing information to clinics, research institutions, clinical research organizations, and healthcare professionals that we engage with for clinical trials.
  • To process job applicants and consideration of employment including working with third party background check provider to conduct necessary background checks.
  • To conduct relevant day to day business operations and adhere to applicable laws and regulations.

 

  • Service Providers.
  • Contractors.
  • External Agencies, and Regulators.
  • Public Authorities / Government as required.
Commercial Information – including but not limited to records of products or services purchased.
  • You (directly from participant).
  • Health Care Practitioners and Service Providers for patient services and customer relationship management.
  • For patient related services including prescription fulfillment, reimbursement, and insurance assistance.
  • For customer support and relationship management including product distribution.
  • To conduct relevant day to day business operations and adhere to applicable laws and regulations.

 

  • Service Providers.
  • Contractors.
  • Distributors.
  • Manufacturers.
Internet or other electronic network activity information – including but not limited to interactions with our websites or advertisements.
  • You (directly from participant).
  • Service Providers
  • To set your website preferences through your online activity gathered through our weblogs and cookies.
  • For educational and marketing purposes about our own commercial and pipeline products and related disease states.
  • To respond to your inquiries and to fulfil your requests.
  • To conduct relevant day to day business operations and adhere to applicable laws.

 

  • Service Providers.
  • Contractors.
  • Share: Third party cookie providers and ad partners
Geolocation Data – IP Address
  • Cookies and other tracking technologies
  • To set your website preferences through your online activity gathered through our weblogs and cookies.
  • To conduct relevant day to day business operations and adhere to applicable laws and regulations.

 

  • Service Providers.
  • Contractors.
  • Share: Third party cookie providers and ad partners
Professional or Employment Information – including, but not limited to professional, educational or employment related information.
  • You (directly from participant).
  • Health Care Practitioners through website or online submissions and information requests.
  • To process job applicants and consideration of employment including working with a third-party background check provider to conduct necessary background checks.
  • To provide you more information on a clinical trial or research.
  • To provide you investor information or compensation.
  • For educational and marketing purposes about our own commercial and pipeline products and related disease states.

 

  • Service Providers.
  • Contractors.
  • Distributors.
  • Manufacturers.
  • External Agencies.
  • External Auditors and Regulators.
  • Public Authorities / Government as required.
Non-public Education Records -including but not limited to education information not publicly available.
  • You (directly from participant).
  • Health Care Practitioners for commercial or product research.
  • To process job applicants and consideration of employment including working with third party background check provider to conduct necessary background checks.
  • To conduct market research on Travere Therapeutics commercial and pipeline products and related disease states.

 

  • Service Providers.
  • Contractors.
  • External Agencies.
  • Public Authorities / Government as required.
Sensitive Personal Information – including but not limited to social security number, health information, medical condition, health data, or protected characteristics.
  • You (directly from participant).
  • Health Care Practitioners and Service Providers for patient services and customer relationship management.
  • Clinical trial participants.
  • For educational and marketing purposes about our own commercial and pipeline products and related disease states.
  • To conduct clinical trials and research including providing information to clinics, research institutions, clinical research organizations, and healthcare professionals that we engage with for clinical trials.
  • To process job applicants and consideration of employment including working with third party background check provider to conduct necessary background checks.
  • With your consent, to post images or photos on our websites and social media platforms.
  • For patient related services including prescription fulfillment, reimbursement, insurance assistance, and patient lab testing.
  • To conduct relevant day to day business operations and adhere to applicable laws and regulations.

 

  • Service Providers.
  • Contractors.
  • Manufacturers.
  • External Auditors and Regulators.
  • Public Authorities / Government as required.

 

As permitted by applicable law, Travere Therapeutics does not treat deidentified data or aggregate consumer information as personal data and reserves the right to convert, or permit others to convert, your personal data into deidentified data or aggregate consumer information. We will not re-identify deidentified data. We also have no obligation to re-identify such information or keep it longer than we need it to respond to your requests.

 

California Minors

Travere Therapeutics’ websites are not directed towards children (under the age of 16). We do not knowingly collect personal data from minors or children through our websites. We also do not knowingly sell or share personal data from minors or children.  Some of our patient services or commercial products process personal data from minors. However, the consent of a parent or guardian is sought in these cases. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us at dataprotection@travere.com or as noted in the contact information listed below.

 

Purposes for collecting and processing personal data

We collect and process personal data to ensure the proper operation of our day-to-day business and for complying with legal obligations.  We collect, use and disclose the following categories of personal data for business purposes: Identifiers, Protected Characteristics, Commercial Information, Internet or Other Electronic Network Activity Information, Professional or Employment Information, Non-Public Education Records, and Sensitive Personal Information.

Our third-party vendors and business partners may themselves engage services providers or subcontractors to enable them to perform services for us, which is considered sub-processing and is an additional business purpose for which we are providing you notice. In addition, we may collect, use and disclose your personal data as required or permitted by applicable law. Notwithstanding anything to the contrary in our general privacy policy, we typically restrict use of your personal data that is disclosed to third parties for business purposes.  We may use and disclose your personal data, including Internet or other electronic network activity information, under this Policy for business or commercial purposes, which may be considered a “Sale” or “Share” under the CCPA, such as when third parties collect and processes your personal data via third-party cookies for certain advertising purposes.  Please see the Your Right to Opt-Out of Sale/Sharing section below or our Cookies Policy or click on the “Do Not Sell or Share My Personal Information” link in each of our website’s footers, for more information on cookies and managing these preferences.

 

Data retention

Travere Therapeutics will retain personal data for only as long as is necessary to fulfill the purposes for which it was collected, including the purposes of satisfying any legal, regulatory, accounting or reporting requirements.  The criteria used to determine Company retention periods for personal data include (i) the length of time we have an ongoing relationship with you; (ii) the amount, nature and sensitivity of the personal data processed; (iii) whether there is a legal or best practice retention obligation to which Travere Therapeutics is subject; and (iv) whether retention is needed in light of litigation or regulatory investigations.

 

California Privacy Rights

We provide California Consumers the privacy rights described in this section.  You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations.  To exercise any of your privacy rights as a California Consumer, please contact us via this form, or call us at +1-888-969-7879 and ask for the Chief Compliance & Privacy Officer.

If you are disabled and need reasonable accommodations to facilitate your request, please contact us.  As permitted by the CCPA, certain requests you submit to us are subject to an identification and verification process.  We will verify identity based on matching information you provided with data we have maintained on you in our systems.  This data could include, but is not limited to, email address, mailing address, or phone number.

We will make commercially reasonable efforts to identify personal data that we collect, process, store, disclose and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests; however, we may charge a reasonable fee if the request is deemed excessive or overly burdensome.  We may also refuse to act upon your request if it is deemed to be repetitive or unfounded. If we determine that your request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision.

Consistent with the CCPA and our interest in the security of your personal data, we will not deliver your actual social security number, driver’s license number or other government-issued identification number, financial account number, any health or medical identification number, an account password, or security questions or answers in response to a CCPA request.

 

Right to Know and Access:

Information Rights:

You have the right to send us a request using one of the methods listed above, up to twice every twelve months, for any of the following:

  • The categories of personal data we have collected about you.
  • The categories of sources from which we collected your personal data.
  • The specific pieces of personal data we have collected about you.
  • The business or commercial purposes for our collecting, selling or sharing your personal data.
  • The categories of third parties to whom we have disclosed your personal data.
  • A list of the categories of personal data disclosed for a business purpose, or that no disclosure occurred.
  • A list of the categories of personal data sold or shared for a business purpose, or that no sale or sharing occurred.

 

Obtaining Copies of Personal Data:

You have the right to make or obtain a transportable copy using one of the methods listed below, up to twice every twelve-months, of your personal data that we have collected and are maintaining.

 

Right to Delete:

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal data that we have collected directly from you and are maintaining using one of the methods listed below.  Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with legal obligations, to engage in research, to exercise or defend legal claims, and to cooperate with law enforcement.

 

Right to Correct:

You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes for which we are processing such personal data.  We will use commercially reasonable efforts to correct such inaccurate personal data about you.

 

Right to Limit Use or Disclosure of Sensitive Personal Data:

You have the right to request that we limit our use of any sensitive personal data we collect to those uses which are necessary to perform our obligations to you or for other specifically enumerated business purposes under the CCPA.  Please note, we do not use or disclose your sensitive personal data beyond our obligations, or the business purposes as defined under the CCPA.

 

Right to Opt-Out of Sale/Sharing:

You have the right to opt-out of the sale of personal data by submitting a request to us.  Please note, we do not believe that we “Sell” personal data as that term is defined under the CCPA.  Where we are sharing your personal data for purposes of cross-context behavioral advertising, you may opt-out of such sharing at any time by clicking on “Do Not Sell or Share My Personal Information” link in each of our website’s footers and changing your cookie preferences using our cookie management tool.  Our cookie management tool enables you to exercise such an opt-out request and enable or disable certain cookie preferences on your devices.  You must update your cookie preferences on each of our websites you visit from each browser and each device that you use.  Since your browser opt-out is designated by a cookie, if you clear cookies, your cookie preferences will no longer be in effect, and you will need to update your cookie preferences again using the cookie management tool.  You can also exercise control over browser-based cookies by adjusting the setting on your browser. You may have to opt-out separately via each browser and device you use. For more information on cookies and other tracking devices and ways to exercise preferences regarding them, see our Cookies Policy.

Alternatively, you may submit a request to opt-out of sharing by activating the “the Global Privacy Control (“GPC”) signal on your browser, but note that it will only apply to the browser on which you set it.

We may disclose your personal data for the following purposes, which are not a “sale” or “share” as defined under the CCPA:

  • You direct us to disclose your personal data;
  • To comply with privacy rights request you submitted;
  • To disclose amongst the entities that constitute us, or to assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business;
  • As otherwise required or permitted by applicable law.

 

Right Not to Be Subject to Discrimination:

You have the right under the CCPA not to be discriminated against for exercising your CCPA rights.  We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.

 

Automatic Decision Making or Profiling:

We do not engage in Automated Decision Making or Profiling as defined by the CCPA.

 

Authorized Agents:

Authorized agents of Consumers may make a request using one of the methods listed above. As permitted by the CCPA, any request you submit to us is subject to an identification and verification process, and confirmation of the agent’s authority, which may include attestation under penalty of perjury.  Absent a power of attorney, we will also require the Consumer to verify their own identity.

 

Limitations on Rights:

Notwithstanding anything to the contrary, we may collect, use and disclose your personal data as required or permitted by applicable law and this may override your CCPA rights.  In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

 

“Shine the Light”

Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

 

Contact Us

If you have any questions about our privacy practices, or if you would like to exercise any privacy rights, please contact us by accessing our webform at https://travere.com/privacy/individualrights, or by calling us at +1-888-969-7879 or by writing to one of the following addresses:

Travere Therapeutics, Inc.
Attn: Chief Compliance & Privacy Officer
3611 Valley Centre Drive, Suite 300
San Diego, CA 92130
USA

Email: dataprotection@travere.com

We will respond to your request consistent with applicable law.

 

Changes to this Policy

We reserve the right, at any time, to modify, alter, or update this Policy, and any such modifications, alterations, or updates will be effective upon posting.

This Policy was last updated on March 31, 2024