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Privacy Policy

Effective March 20, 2020

Catalyst Pharmaceuticals, Inc. (“Catalyst”) is committed to protecting any personal information we maintain about you. This Privacy Policy (this “Policy) is designed to help you understand the types of information we may collect about you and how we use it.  This Policy applies to information Catalyst collects both online and offline.  We collect information online through our websites, www.catalystpharma.com, www.yourcatalystpathways.com, www.firdapse.com, www.firdapsehcp.com. In the offline context, we may collect information via mail, telephone, or in person. California residents can scroll down for additional specific information about their rights under the California Consumer Privacy Act.

 

Information Collected

We collect certain personal information from visitors to our website if they choose to provide it to us.  For example, we collect name, e-mail address, telephone number, and mailing address through the “contact us” and “sign up” features on our websites.  We collect additional personal information from customers that complete an “enrollment form” for our Catalyst PathwaysTM program such as date of birth, health insurance information, and medical information.

We also collect information about the browser and/or device you use to access our website (such as the type of browser or device you are using, browser settings, and the device identification number). Device information may or may not be personally identifiable depending upon whether it is linked to the identity of the user.

We may automatically log information, such as your IP address, domain name, browser type, date and time of access, and other log file data. This information may be used to analyze trends or administer our websites. We may collect statistical or non-personally identifiable information about our users, such as which pages are visited, how long a visitor stays on a particular page, the website from which a user came to our site, or similar such information. We also may collect aggregate information such as the total number of unique or return visitors to our sites or visiting a particular page in a given timeframe. We may use this information to measure the use of our sites and to improve our content. We may use Google Analytics, a third-party provider of analytics tools or a similar third-party service to analyze information about visits to our website. For information about opting out of Google Analytics please visit: https://tools.google.com/dlpage/gaoptout.

 

Cookies

Our websites may utilize “cookies,” web beacons, and other similar technologies. We may use first and/or third party “browser” or “HTTP” cookies, which are unique text files that may be used for data analysis and enable our website to tailor information for the visitor. We may use browser cookies for purposes such as to personalize the user’s experience on our site, to remember a user when the user registers for products or services, for fraud prevention, or to track visits to our websites. We also may use “web beacons” (also referred to as pixel tags, clear gifs or other terms) or similar technologies to collect information such as how long a visitor remains on a particular page. 

If you would like to opt-out of the placement of cookies you can do so using your website browser’s cookie control features.  Opting out of the placement of cookies, however, may limit your ability to use some of the features of our site.  Our site does not currently respond to do-not track signals.

 

Use of Collected Information

We may use the information we collect through our websites for the following purposes:

  • To provide information that patients, providers or other users of our websites or services may request;
  • To communicate with providers, patients and caregivers who have contacted us;
  • To provide our customers with products and services they request;
  • To administer our patient support and/or patient assistance programs;
  • To meet our regulatory obligations;
  • To improve and administer our websites;
  • To better understand the needs of patients and providers;
  • To generate statistics and de-identified data;
  • To enforce the terms of use for our website;
  • For historical, statistical or business planning purposes;
  • To prevent fraud and investigate potential misconduct; or
  • To comply with law and legal process.

 

Disclosure of Collected Information

Catalyst may disclose personal information for a variety of purposes, including:

  • We may disclose information we collect to our service providers providing services on our behalf. 
  • We may share information with health care providers in the course of administering our patient support and/or patient assistance programs.
  • We may disclose information to the Food and Drug Administration or other regulators to meet our regulatory obligations.
  • In the event that our company or some of our assets are sold or transferred or used as security or to the extent we engage in business negotiations with our business partners, the personal information we collect may be transferred or shared with third parties as part of that transaction or negotiation. 
  • If we receive a request from law enforcement officials or judicial authorities to provide information on individuals, we may provide such information. 
  • In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use or disclose your personal information without a court order. 
  • We may also use information you submit to investigate security breaches, misconduct, or otherwise cooperate with authorities pursuant to a legal matter. 

 

Sale of Collected Information

Catalyst does not sell personal information to third parties.

 

Safeguarding Your Information

Catalyst understands the importance of data security and we take reasonable measures that we believe are appropriate to protect your information from loss, misuse, alteration, or destruction. 

 

Your Choices Regarding Collection and Use of Your Information

In cases where you are requested to affirmatively provide information, such as to complete a form or an application on our website, you may decline to do so. Please understand, however, that in some cases certain information is required to complete a form of application and if you decline to provide the information requested you may not be able to submit the application or request or to use certain functionalities of our websites or mobile applications. If you would like to restrict our placement of cookies on your device, please see the “Cookies” section above. If you would prefer to no longer receive e-mail marketing messages from us, please use the opt-out instructions included in the email message to opt-out of additional communications.

 

Third Party Websites

Some of our websites contain links to third party websites not owned by Catalyst Pharmaceuticals or governed by our privacy policy. Please be aware that sites we link to may collect information about you and operate according to their own privacy practices which may differ from this Policy. Remember to consult the privacy policy of any website you may visit regarding their privacy practices.

 

Personal Information of Children

Catalyst’s services, products, and websites are not directed at or marketed to children under the age of 13. We do not knowing collect personal information from or about children. If we learn we have inadvertently collected personal information from a child under the age of 13, we will remove the information from our files.

 

Changes to This Policy

If we make material changes to this Policy, we will change the “last updated” date so that you can easily determine whether material changes have been made since the last time you reviewed the Policy.

 

Point of Contact

If you have any questions about our privacy policy and our privacy practices, please contact us at:

 

California Residents: Your Rights

You have the right to know, without making a request, the categories of personal information Catalyst has collected and disclosed about its consumers within the last twelve (12) months. The chart below offers a comprehensive overview of the types of personal information we collect, with whom we share it, and for what purpose.

Category Examples

Collected

[YES/NO]

Source of Collection Purpose for Collection Third Parties to Whom Disclosed
Identifiers. A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. YES Catalyst Pathways Enrollment form, internet submissions of request for more information, and opting into receipt of marketing information. To enroll new patients in Catalyst Pathways and to be able to respond to requests directly. Vendors supporting Catalyst Pathways by providing services to or on behalf of patients and vendors supporting our marketing programs.
Personal information categories listed in the California Customer Records statute. A name, signature, physical characteristics or description, address, telephone number,  insurance policy number, medical information, or health insurance information. YES Catalyst Pathways Enrollment form, internet submissions of request for more information, and opting into receipt of marketing information. Catalyst Pathways Enrollment form, internet submissions of request for more information, and opting into receipt of marketing information. Vendors supporting Catalyst Pathways by providing services to or on behalf of patients and vendors supporting our marketing programs.
Protected classification characteristics under California or federal law. Age (40 years or older), marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), genetic information (including familial genetic information). YES Catalyst Pathways enrollment form Upon enrollment in Catalyst Pathways, Catalyst (or its vendors) gather this information to assist in the delivery of services. Vendors supporting Catalyst Pathways by providing services to or on behalf of patients.
Commercial information. Records of products purchased, obtained, or considered.  YES Business operation activities Either on our own or through our vendors we maintain records of purchases of our products by patients. AnovoRx Specialty Pharmacy (as our contracted pharmacy)
Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES Once a person submits info to request info or to allow for updates, their anonymous interactions with our website (time, frequency, etc.) are tracked in cumulative totals.  Also, we track what search engine or advertisement led the person to our website. To provide for analytics on the traffic and usefulness of our websites. Our marketing vendor tracks this and reports anonymous data to us.
Sensory data. Audio (i.e. recording phone calls). YES Service calls to and from Catalyst Pathways Calls with patients by Catalyst Pathways personnel are recorded and archived both for assessment of service quality and also for compliance review. Our vendor supporting our Catalyst Pathways patient services hub.
Professional or employment-related information. Current or past job history or performance evaluations. YES Directly from applicant. To evaluate applicants for employment. Vendor that provides background checks and verifies employment and educational info as well as verifying references.

Sale of Personal Information

Catalyst Pharmaceuticals does not sell personal information. 

 

Right to Know About Personal Information Collected or Disclosed

You have the right to request that Catalyst Pharmaceuticals disclose certain information to you about our collection, use, and disclosure of your personal information over the past twelve (12) months. Once we receive and confirm your request, to the extent you have requested them, we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom we share that personal information; and
  • The specific pieces of personal information we have collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, a list identifying the categories of personal information disclosed about you to each category of third party.

 

Right to Request Deletion of Personal Information

You have the right to request that Catalyst Pharmaceuticals delete any of your personal information that we have collected from you and maintain, subject to certain exceptions. Once we receive and confirm your request, we will delete, de-identify, or aggregate your personal information, unless retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our business relationship with you, or otherwise perform our 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 free speech or ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • 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 is likely to render impossible or seriously impair the achievement of such research, 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.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Your Rights to Know and Deletion

To exercise your right to know or your right to delete please submit a request to [email protected] or call the following toll-free telephone number: 1 (844) 347-2773.

In your consumer request, please provide sufficient information such that we are able to reasonably verify you are the person about whom we collected personal information. Only you, or someone legally authorized to act on your behalf (i.e., your authorized agent), may make a request related to your personal information. Catalyst may ask that an agent provide verification that they are acting on behalf of a consumer. 

 

Non-Discrimination

Catalyst will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you services.
  • Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of services.

 

Contact Information

If you have any questions or comments about this privacy policy, the ways in which Catalyst collects and uses your information, your rights regarding such use, or wish to exercise your rights under California law, please contact us at: