Consumer Health Data Privacy Policy
For Residents of Washington and Nevada
This Consumer Health Data Privacy Policy is intended for residents of Washington pursuant to 2023 Wash. Laws 191 (“My Health My Data Act”) and for residents of Nevada (pursuant to SB 370).
Categories of Information and Sources
Bavarian Nordic collects certain consumer health data and information in the following categories:
- Information that you submit to Bavarian Nordic by sending e-mails to Bavarian Nordic, calling Bavarian Nordic, posting or commenting on websites or social media owned or maintained by Bavarian Nordic, or by signing up for voluntary Bavarian Nordic programs or opting in. This includes only the information that you provide and may include your health information, or information that may reveal your past, present, or future health status, interest in certain medications or interest in accessing health care or receiving health services or supplies.
- Information about visitors to our websites and those who click on our advertisements. This data may include your IP address, general location, and previous interactions with Bavarian Nordic or other browsing history, but this data does not identify you by name. This information could potentially include information that may reveal your past, present, or future health status, interest in certain medications or interest in accessing health care or receiving health services or supplies. This information may be collected by third parties over time and across different Internet websites or online services when you use any Internet website or online service of Bavarian Nordic and accept the default settings. You may opt out from some information collection on our websites by clicking on the link to manage your privacy preferences or declining to accept cookies; however, if you opt out, you may not be able to have the intended experience on our websites or Internet-based services.
- Information provided to Bavarian Nordic by your health care professionals or that you or they submit to the government related to adverse events, potential side effects or product quality complaints or concerns. This information is not subject to state law because Bavarian Nordic is required to maintain this information under federal law to evaluate and monitor the safety of our products.
- Information from patients who participate in clinical trials sponsored by Bavarian Nordic or sponsored by independent investigators and supported by Bavarian Nordic. This information is not subject to correction, disclosure or deletion under state law because Bavarian Nordic is required to follow federal laws regarding the maintenance and protection of clinical trial data.
- Information you provide or are gathered relating to you as an applicant for employment, employee, consultant or contractor of Bavarian Nordic. This information is not subject to the state laws relating to consumer health information.
In addition to product safety and product quality data, data may also be utilized for providing you a more customized experience and for improving the relevance of the advertising, education or informational communications you receive. Data utilized for analytics for improving our products, services and activities will be shared at an aggregate level and will not be individually identifiable.
We will use commercially reasonable efforts to protect data relating to your health information from unauthorized access and will limit access to only individuals who need access to the information to provide, improve or analyze our products, services, and activities.
Sale of Consumer Health Data
Bavarian Nordic will not sell your consumer health data. In the event that Bavarian Nordic or its assets are purchased by another company, we may transfer your information to the purchaser company.
Sharing of Consumer Health Data
Information you or your healthcare provider provide may be shared with our affiliates or parent company, Bavarian Nordic A/S, or our employees or contractors, for the purposes of managing or responding to your inquiry, fulfilling the services you requested, or for fulfilling our legal obligations with respect to monitoring the safety and quality of our products. We may share your information on a limited basis with our vendors who help to fulfill our marketing and advertising programs, manage data for Bavarian Nordic, provide data analysis services to Bavarian Nordic, or who maintain our websites. The third parties who may receive information may depend on the purpose for which you provided your information or for which it was gathered and may change over time. You may request a list of any third parties that have received your consumer health data using the mechanisms below. We will only provide your information to government agencies or other third parties if required or authorized by law, if it is required for the purposes stated above, or if you have consented.
Your Rights Under State Law
You have the right to confirm whether Bavarian Nordic is collecting, sharing, or selling consumer health data concerning you and to access such data. You have the right to withdraw consent from collection and sharing of consumer health data concerning you. You have the right to request that certain information be deleted. If we are not able to delete your data because it is not included under state law, we will let you know. If we are not able to authenticate your request using commercially reasonable efforts, we will not be able to honor the request or may request additional information.
You may receive information up to twice annually per consumer. Bavarian Nordic cannot reply to requests that are unfounded, excessive or repetitive.
You may submit your request to exercise your rights under state law by emailing USPrivacy@bavarian-nordic.com, or by calling 1-877-882-7434. Please include your state of residence and information sufficient to authenticate and respond to your request.
Appeals
If we decline your request, you may submit an appeal to legal@bavarian-nordic.com.
Changes to This Policy
This policy may be revised from time to time. The revised policy will be posted online and will have a revised “Last Updated” notice at the bottom, which will indicate that the terms of this policy have changed.
Non-Discrimination
Bavarian Nordic will not consider whether you have exercised any of your rights under state law in determining whether Bavarian Nordic can fulfill your request or provide you products or services and will not otherwise discriminate against individuals who exercise their rights under the aforementioned state laws.
Last Updated: March 2024