Travere Therapeutics, Inc., and its subsidiaries (“Travere Therapeutics,” “Company,” or “we”) is a biopharmaceutical company specializing in identifying, developing, and delivering life changing therapies to people living with rare diseases. We process personal data in different contexts and we do so by fully respecting your privacy and your other rights and freedoms, as part of our unwavering commitment to ethical and responsible practices. We process personal data collected through our websites; we gather personal data for marketing and educational purposes; we process personal data for conducting clinical trials and we process the personal data of our employees. We recognize that innovation and new technology drive continual change in risk, expectations, and laws, so we follow privacy accountability standards and aim to promptly adapt how we apply those standards in response to those changes.
In principle: Travere Therapeutics collects, uses and stores the minimum amount of personal data that you voluntarily submit to Travere Therapeutics that is necessary for one or more legitimate business purposes and to comply with legal obligations. Travere Therapeutics limits who has access to the personal data in our possession to only those who need it for a legitimate business purpose or if required by law. Travere Therapeutics protects personal data through physical and technical security measures tailored to the sensitivity of the personal data we hold. Travere Therapeutics communicates with our employees, customers, suppliers, business partners and others about how we intend to use personal data in our day-to-day operations. Travere Therapeutics takes reasonable steps to ensure the personal data we process is accurate and up to date. Travere Therapeutics integrates privacy in the design of our projects that involve the use of personal data.
For European Economic Area (“EEA”), United Kingdom and Swiss data protection law purposes, we process personal data as a controller or joint controller, depending on the context of the processing activity. The controller is the entity that, alone or jointly with others, establishes the purposes and the means of a processing activity. A “processing activity” is an activity that we engage in for a specific, identified purpose, and that involves the collection and use of personal data.
When transferring personal data from the EEA, United Kingdom or Switzerland to the United States, Travere Therapeutics utilizes standard contractual clauses or other lawful grounds for transfers since the United States has not been found to have adequate data protection laws by these jurisdictions. Travere Therapeutics also complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EEA, the United Kingdom, and Switzerland to the United States. Participation in Privacy Shield served as a legal basis for transfers of personal data to the United States prior to July 16, 2020 (September 8, 2020 for Switzerland). While Privacy Shield no longer serves as a basis for transfers of personal data to the United States, Travere Therapeutics continues to participate in Privacy Shield to demonstrate its support for additional protections for personal data transferred from these jurisdictions.
Who We Are
We are Travere Therapeutics, Inc., and you can contact us via mail at 3611 Valley Centre Drive, Suite 300, San Diego, CA 92130, Attn: Chief Compliance Officer, via email at email@example.com, or you can call us at +1-888-969-7879. For data protection purposes, including the EEA, United Kingdom and Swiss data protection laws, we are the controller of your personal data, and you can contact us with any inquiries you may have regarding the processing of your personal data.
Types of Personal Data we Collect and Use
“Personal data,” means any information related to an identified or identifiable individual. Depending on the context in which we process your personal data, we collect and otherwise process the following, by way of example and not limited to:
Information that you provide via a Travere Therapeutics website or by some other method such as email or telephone and that can directly or indirectly identify or locate you: name, address, telephone number, e-mail address, and any other related information you submit to us. Information that a Travere Therapeutics website collects automatically: the date and time of the website session, movements across the website, information about your browser, your IP address, and information related to your online activity gathered through our weblogs and cookies. Personal data, including data related to an individuals’ health or a clinical trial. Employment details and history, biographical information, educational history, benefits, compensation, contact details, performance, and use of Company resources by employees, contractors, and applicants in connection with their role or potential role for Travere Therapeutics. Contact information for key personnel of customers and potential customers for the purpose of performing sales, services, education, customer support, analytics, research, and marketing. Social security numbers to the extent necessary for compensation and/or Travere Therapeutics products and services.
Our Policy Towards Children:
Our websites are not directed towards children. We do not knowingly collect personal data from children through our websites. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child is using our websites and has provided us with personal data, we will delete such information from our files. Some of our clinical trials, patient services and commercial products process personal data of children. The consent of parents or legal representatives is sought in these cases, and in accordance with the laws where the activities are being conducted.
What We Do With Your Personal Data
In the case of clinical trials, we collect, store and analyze your personal data generated via clinical trials we are conducting utilizing clinics, research institutions, clinical research organizations, and healthcare professionals that we contract with.
For the processing of social security numbers, Travere Therapeutics has implemented reasonable technical, physical and administrative safeguards to help protect the social security numbers and other sensitive personal information from unlawful use and unauthorized disclosure. All Travere Therapeutics employees are required to follow these established procedures, both online and offline. In particular, access to social security numbers is limited to those employees and service providers who have a need to access this information to perform tasks for Travere Therapeutics. We will only disclose social security numbers with those service providers, auditors, advisors, and/or successors in interest who are legally or contractually obligated to protect them, or as required or permitted by law.
Purposes for Collecting and Processing Personal Data
The purposes for which we collect and process your personal data are:
To ensure the proper operation of our day-to-day business and for complying with legal obligations. To respond to your requests for information, products, and/or services. If you apply for a job via our career center, to consider you for employment. To contact you and provide you with disease state, product, and general services information. If you have a business or professional relationship with Travere Therapeutics, we may use your personal information generally to develop our business relationship with you and/or further the advancement of services. For legal and compliance obligations, such as adverse event reporting and for other everyday business purposes, such as website management, research and development, educational, and commercial purposes.
Grounds for Processing
For those processing activities that fall under the EEA, United Kingdom and Swiss data protection laws, the legitimate grounds for processing personal data that Travere Therapeutics relies on are:
Consent for our clinical trials, for the collection and use of data through our website and for personal data processed for marketing and educational purposes. To fulfill our legitimate business and healthcare initiative interests. The necessity to enter a contract, where appropriate and for compliance with legal obligations.
Who Has Access to Your Data
Except as provided herein, Travere Therapeutics will not share your personal data with third parties unless you have consented to the disclosure. We only share your personal data with our agents, contractors or partners in connection with services that these individuals or entities perform for, or with, Travere Therapeutics such as: sending e-mail messages, managing personal data, hosting our databases, providing personal data processing services, providing customer service, and facilitating the job application process.
These agents, contractors or partners are restricted from using one’s personal data in any way other than to provide services for Travere Therapeutics, or services for the collaboration in which they and Travere Therapeutics are engaged (for example, some of our products are developed and marketed through joint agreements with other companies). For the purposes of applicable data protection laws, Travere Therapeutics enters controller-processor arrangements with our agents, contractors or partners that qualify as processor.
Travere Therapeutics will share personal data to respond to duly authorized subpoenas or other lawful information requests of governmental authorities, including to meet national security or law enforcement requirements, or where required by law. In exceptionally rare circumstances where national, state or Company security is at issue, Travere Therapeutics reserves the right to share our entire database of visitors and customers with appropriate governmental authorities.
Transfer of Data Overseas & Privacy Shield Principles
If you are located outside the United States (U.S.) and you interact with us via one of our websites, mail, e-mail, phone, or you participate in one of our clinical trials, then your personal data is transferred to the U.S. If you are based in the EEA, United Kingdom, or Switzerland, please be informed that the U.S. did not obtain an adequacy decision for the level of protection afforded to personal data. However, we provide appropriate safeguards for your data in the U.S. We utilize your consent, standard contractual clauses, or other lawful grounds for transferring personal data to the United States. As discussed above, we also participate in the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks, although these programs no longer serve as our lawful basis for transferring personal data to the United States.
Privacy Shield and its Principles:
In compliance with the Privacy Shield Principles, Travere Therapeutics commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Travere Therapeutics at:
Travere Therapeutics, Inc.
3611 Valley Centre Drive, Suite 300
San Diego, CA 92130
Attn: Chief Compliance Officer
Or call: +1-888-969-7879 or +1-858-832-2812
Or e-mail: firstname.lastname@example.org
If, after attempting to address privacy questions or concerns with Travere Therapeutics directly you still have a specific privacy concern that has not been resolved, you may choose to mediate your concern by a neutral third party. Travere Therapeutics has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.adr.org for more information or to file a complaint. The services of the American Arbitration Association are provided at no cost to you.
American Arbitration Association
Case Filing Services
877.495.4185: Toll free
Contact your Data Protection Authority: If you are based in the EEA or United Kingdom, you may choose to contact your local Data Protection Authority (“DPA”), or the Swiss Federal Data Protection and Information Commissioner (“FDPIC”), if you are based in Switzerland. Your DPA or the FDPIC may refer your complaint directly to the U.S. Department of Commerce on your behalf. In this case, the Privacy Shield Team will then work to resolve your concern. Travere Therapeutics commits to cooperate with the EEA and United Kingdom DPAs and the Swiss FDPIC and to comply with the advice given by such authorities with regard to human resources data transferred from the EEA, United Kingdom and Switzerland in the context of the employment relationship.
U.S. Department of Commerce’s Privacy Shield Framework: you may also have the option to select binding arbitration for the resolution of your complaint under certain circumstances. For more information on binding arbitration, see U.S. Department of Commerce’s Privacy Shield Framework.
For purposes of enforcing compliance with Privacy Shield, Travere Therapeutics is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. For more information about Privacy Shield and to view Travere Therapeutics’ certification page, please visit https://www.privacyshield.gov.
In the context of an onward transfer, Travere Therapeutics has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Travere Therapeutics shall remain liable under the Privacy Shield Principles if its agent processes such personal data in a manner inconsistent with the Principles unless Travere Therapeutics is not responsible for the event giving rise to the damage.
California Consumer Privacy Act
How Do You Control Your Data
Whether you reside in the U.S., reside in or otherwise find yourself in the EEA, United Kingdom or Switzerland, Travere Therapeutics is committed to facilitate the exercise of your rights granted by applicable European data protection laws and our commitment to privacy, noted above, in a timely manner – the right to access your data, to ask for erasure, correction, portability of your data or to object to the processing of your data. In order to be able to reply to your request and if we are not certain of your identity, we may need to ask you for further identification data to be used only for the purposes of replying to your request. If you would like to exercise any individual privacy rights, please contact us via this form, or you can call us at +1-888-969-7879 and ask for the chief compliance officer.
Access to Your Own Personal Data:
You have the right to obtain confirmation of your personal data whether we process it or not, as well as the right to obtain information about the personal data we process about you and to obtain a copy of this data.
Erasure, Correction and Other Requests including Receiving Communications:
You have the right to obtain erasure, correction, and portability of your personal data, under certain conditions. You also have the right to object at any time to receiving marketing/educational materials from us by following the opt-out instructions in our e-mails, as well as the right to object to any processing of your personal data based on your specific situation. In the latter case, we will assess your request and provide a reply in a timely manner, according to our legal obligations.
Please be sure to include your e-mail address if you are writing to unsubscribe from any service or materials we provide you. Also, please note that you may continue to receive materials while we are updating our lists. For all the processing operations that are based on your consent, as described above, you can withdraw consent at any time and we will stop those processing operations. All processing of your personal data based on your consent before withdrawal remains lawful. As to adverse event reporting and related personal data, Travere Therapeutics reserves the right to not remove or amend such personal data and/or adverse event information as required by law or regulation. Travere Therapeutics does not engage solely in automated decision making or profiling using your personal data.
We are committed to processing your personal data in a secure manner, by creating specific technical and organizational measures to prevent the personal data we hold from being accidentally or deliberately compromised.
Acceptance of Terms
Changes to this Notice