Boehringer Ingelheim US Privacy Policy Statement

Last Updated: March 21, 2024

 

A. Welcome

Thank you for visiting us. We have revised our Privacy Statement (“Privacy Statement”) to make it clearer and more user-friendly and transparent about how we process information we collect about you (“Personal Data”). We respect and protect your privacy, and we are committed to the transparent use of your Personal Data.

This Privacy Statement informs you of how we collect and use your Personal Data when you use our websites or mobile applications, or otherwise interact with us online or offline (collectively, the “Services”) provided by Boehringer Ingelheim US (“Boehringer”). This Privacy Statement may change from time to time as our websites and business evolve, and we will post the updated notice on this page. If we make any material changes to this Privacy Statement, we will notify you if we are required to do so by applicable law. 

 

B. Scope

This Privacy Statement applies to all Personal Data we collect from U.S. consumers, such as U.S. individuals who visit our websites, use our mobile applications, and otherwise use our Services. This Privacy Statement does not apply to Boehringer employees, job applicants, or other individuals with whom we interact in an employment-related capacity (collectively, “Employees/Applicants”) or to individuals with whom we interact in a business context, including healthcare professionals (collectively, “Business Contacts”). Employees/Applicants can view our privacy statements applicable to them at the below links:

• Employee/Applicant Privacy Statement

 

C. What is Personal Data?

Personal Data means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular living person or household. Personal Data does not include anonymized or publicly available data, or any other categories of information that are excluded from the definition of “Personal Data” under applicable U.S. privacy laws (“U.S. Privacy Laws”). References to Personal Data in this Privacy Statement include “Sensitive Personal Data,” as defined below, except where noted otherwise.

We collect and have collected in the past twelve months the following categories of Personal Data:

• Identifiers - Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, phone number, email address, account name and login credentials, driver’s license number, or other government-issued identifiers.

• Financial Information - Financial information, including bank account number, credit or debit card number, or other financial information.

• Health Insurance Information - Health insurance information, including an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history.

• Protected Characteristics - Characteristics of protected classifications under state or federal law, such as race, gender, physical or mental disability, and religion.

• Commercial Information - Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Biometric Information - Biometric information, including an individual’s physiological, biological, or behavioral characteristics (including DNA) to the extent it can be used to establish individual identity. Biometric information consists of, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template (such as a faceprint, a minutiae template, or a voiceprint) can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

• Network Activity Data - Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.

• Geolocation Data - An individual’s approximate or precise geolocation data.

• Electronic and Sensory Data - Audio, electronic, visual, thermal, olfactory, or similar information (e.g., a recording of a customer service call or profile photograph). This also includes the contents of your messages, chats, or other communications that you send to us or through the website.

• Professional Information - An individual’s professional or employment-related information.

• Education Information - An individual’s education information, including academic information and records.

• Inferences – Inferences drawn from any of the categories of Personal Data listed in this Section C to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• Sensitive Personal Data - The above categories include types of Personal Data that may be considered “sensitive” in some jurisdictions such as biometric information, communications or messages content, financial information, login credentials, government-issued identifiers, health insurance and medical information, and protected characteristics. Further, we collect the following categories of health-related information: Individual health conditions, treatment, diseases, or diagnosis; Social, psychological, behavioral, and medical interventions; Health-related surgeries or procedures; Use or purchase of prescribed medication; Bodily functions, vital signs, symptoms, or measurements related to health; Diagnoses or diagnostic testing, treatment, or medication; Reproductive or sexual health information; Biometric data; Genetic data; Precise location information that could reasonably indicate a consumer's attempt to acquire or receive health services or supplies; Data that identifies a Consumer seeking health care services; Health-related data that have been derived or inferred from the above 

 

D. Purposes for Processing Personal Data

We collect, use, and disclose Personal Data (except for Sensitive Personal Data) to:

• Respond to requests from you

• Better understand your needs and improve our websites, products, and services

• Analyze the use of our Services, and to operate and maintain our business

• Contact you, including providing you with information, opportunities, updates, and special offers from Boehringer and our business partners

• Prepare for and conduct research 

• Monitor the safety and efficacy of our products or services

• Monitor, investigate potential breaches of, and enforce compliance with Boehringer policies and procedures and legal and regulatory requirements

• Respond to and comply with legal process, such as civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons

• Exercise or defend the legal rights of Boehringer and its employees, affiliates, customers, contractors, agents, and others 

• Comply with legal obligations, regulatory requirements, and our own policies and procedures

 

E. Purposes for Processing Sensitive Personal Data

We collect, use, and disclose Sensitive Personal Data for the below purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services

• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Data

• To resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions

• To ensure the physical safety of natural persons

• To perform services on behalf of our business, such as for maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business

• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us

• To collect or process Sensitive Personal Data where the collection or processing is not for the purpose of inferring characteristics about a consumer

Please note that we do not collect, use, or disclose Sensitive Personal Data for purposes other than those specified in the California Consumer Privacy Act (“CCPA”).

 

F. Sale, Sharing, & Targeted Advertising

We sell, share, and process Personal Data for purposes of targeted advertising, and we have sold, shared, and processed Personal Data for purposes of targeted advertising in the past twelve months, as described in the below chart, as the terms “sale,” “share,” and “targeted advertising” are defined by U.S. Privacy Laws. You have the right to opt out of the sale, sharing, and/or processing of your Personal Data for targeted advertising. To do so, you can click here or call us at 1-800-243-0127.

 

Category of Personal Data

Disclosed to Which Categories of Third Parties

Name, Contact Information, and Identifiers

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Protected Characteristics

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Commercial Information 

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Biometric Information

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Network Activity Data

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Geolocation Data

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Electronic and Sensory Data

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Professional and Education Information

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Medical Information

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Inferences and Profiles

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

Sensitive Personal Information, Health Information, Financial Information

Boehringer's subsidiaries and affiliate companies; providers; professional advisors; public and government entities

 

We sell, share, and process Personal Data for purposes of targeted advertising as described above to:

• Better understand your needs and improve our websites, products, and services

• Analyze the use of our Services, and to operate and maintain our business

• Contact you, including providing you with information, opportunities, updates, and special offers from Boehringer and our business partners

Please note that we do not have actual knowledge that we sell or share the Personal Data of children under the age of sixteen.

 

G. Personal Data Retention and Minimization

Boehringer uses only the minimum amount of Personal Data reasonably necessary to accomplish the purpose for which it was collected. Further, we retain your Personal Data for as long as necessary to fulfill the purposes for which they are collected or to satisfy a legal obligation imposed on Boehringer. Personal Data that are no longer needed for the above purposes will be deleted or deidentified. Whenever we deidentify Personal Data, we take reasonable measures to ensure that the information cannot be associated with a consumer or household, and we maintain and use the information in deidentified form. We will not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether our deidentification processes satisfy applicable legal requirements.

 

H. Sources from which We Collect Personal Data

We collect Personal Data directly from consumers. For instance, you may disclose Personal Data to us to receive information, opportunities, updates, or special offers from Boehringer and its business partners. You can also ask us about our products or services, or someone can ask for them for you. You may want to join one of our programs or be part of a patient community that we support. Also, some Services offer interactive content, like patient education and support. Users of the Services may provide Personal Data to Boehringer to experience these features. We also collect Personal Data from our vendors and from third parties when they disclose Personal Data to us, as well as from joint marketing partners, publicly-available sources, and social media.

Further, we collect Personal Data via cookies and similar technologies on our Services. Websites use these technologies for different reasons, such as to provide, improve, measure, personalize, or share online services with you. We use cookies to improve website functionality, performance, and other cookies to remember your preferences or to show relevant content. You can review, modify, or revoke your consent to cookies by customizing your preferences in the cookie preference center of our websites.

 

I. Disclosures of Personal Data

We disclose, and we have disclosed in the past twelve months for a business purpose, the categories of Personal Data listed in Section C to:

• Our parent company and affiliates

• Our vendors who process Personal Data to provide services on our behalf

• Third party marketing partners who conduct online targeted advertising

• Other third parties: With your consent or at your direction; In connection with a sale, reorganization, joint venture, or other similar business transaction; Government and regulatory bodies and courts to comply with our legal and regulatory obligations, ensure compliance with the requirements of our policies and procedures, or prevent fraud or physical harm

 

J. Protecting Personal Data

Boehringer implements technical, physical, and administrative protections to keep Personal Data secure. However, despite these protections, no organization, including Boehringer, can completely guarantee that your Personal Data are not accessed by unauthorized people/bad actors. If Boehringer becomes aware that Personal Data has been compromised, Boehringer will promptly take steps to resolve the incident in accordance with applicable laws and regulations.

 

K. Personal Data of Minors

Boehringer is committed to protecting the privacy of children. Our Services are not geared toward children under the age of 18. Further, for compliance with the Children’s Online Privacy Protection Act, we do not collect Personal Data from children under 13 years old without the express consent of the child’s parent or guardian. If you are the parent or guardian of a child under 13 years old and you believe that we have collected Personal Data about your child without your consent, please contact us immediately at us.privacy@boehringer-ingelheim.com and we will promptly take steps to delete such Personal Data from our systems.

 

L. Exercising Data Subject Rights

Depending on your place of residence, including California, Connecticut, Colorado, Delaware, Indiana, Iowa,  Montana, New Jersey, New Hampshire, Oregon, Tennessee, Texas, Utah, and Virginia, you may have some or all of the following rights (“Data Subject Rights”). You may exercise your Data Subject Rights by any of the methods provided in the “Contact Us” section, below. 

You may also authorize an agent to make data subject requests on your behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. To verify your identity and protect your Personal Information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you, or asking you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law. 

• Right to Know or Confirm Processing. Before or at the time we collect Personal Data from you, you have the right to receive notice of the Personal Data to be collected and the purposes for which we use it. This Supplemental Notice is intended to satisfy this requirement. Additionally, you may have the right to confirm whether we are processing your Personal Data. You also have the right to request that we disclose to you the categories of Personal Data we have collected about you, the categories of sources from which the Personal Data was collected, the business or commercial purpose for collecting, selling, or sharing the Personal Data, and the categories of third parties with whom we disclosed the Personal Data.

• Right of Access or Data Portability. You have the right to request that we disclose or provide you with access to or a copy of the specific pieces of Personal Data we have collected about you.

• Right to Deletion. You have the right to request that we delete the Personal Data we collect from you. However, in certain situations, we are not required to delete your Personal Data, such as when the information is necessary to complete the transaction for which the Personal Data was collected, to provide a good or service requested by you, to comply with a legal obligation, or for other reasons as allowed under applicable law.

• Right to Correct. You have the right to request that we correct your Personal Data if you believe it is inaccurate or incomplete. 

• Right to Opt Out of Sale, Sharing, and Processing of Personal Data for Targeted Advertising. You have the right to opt out of the sale, sharing, and processing of your Personal Data for targeted advertising. To do so, you can click here or call us at 1-800-243-0127. 

• Right to Opt Out of Profiling. Some U.S. Privacy Laws give consumers the right to opt out of profiling of Personal Data that has legal or similarly significant effects. Please note that we do not process Personal Data for profiling with legal or similarly significant effects. 

• Right to Revoke Your Consent. Depending on your state of residence, your consent may be required in order for us to engage in certain processing activities. If we have obtained your consent for this purpose, you have the right to revoke it at any time. 

• Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your Data Subject Rights as described above. We will not discriminate or retaliate against you for exercising your Data Subject Rights.

If we deny your request to exercise a Data Subject Right, you may have the right to appeal the decision with us, depending on your state of residency. Please be sure to include information about your prior request so that we may locate our earlier determination and appropriately respond to your request. We will process your appeal in accordance with the U.S. Privacy Law that applies to you.

 

M. Do Not Track & Opt-Out Preference Signals

We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by U.S. Privacy Laws, we treat such opt-out preference signals as a valid request to opt-out of sale, sharing, and processing for purposes of targeted advertising, as applicable, for the browser or device through which the signal is sent and any consumer profile we have associated with that browser or device, including pseudonymous profiles. Further, if we know the identity of the consumer from the opt-out preference signal, we will also treat the opt-out preference signal as a valid request to opt out of sale and sharing for such consumer. Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit.

 

N. Other State-Specific Disclosures

• California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of our Services, you may ask us to remove content or data that you have posted to the Services by writing to us.privacy@boehringer-ingelheim.com. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.

• Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of personal information to other entities for their direct marketing purposes in the preceding calendar year. To make such a request, please send an email to us.privacy@boehringer-ingelheim.com with the subject “Shine the Light Request.”

• Financial Incentives for California Consumers. We do not provide financial incentives to California consumers who allow us to collect, retain, sell, or share their personal information. We will describe such programs to you if and when we offer them to you.

• Disclosure for Nevada Consumers. We sell “Covered Information” as defined under Nevada law, but we generally do not disclose or share “Personal Information” as defined under Nevada law for commercial purposes. Under Nevada law, you have the right to direct us to not sell your Covered Information to third parties, as defined under Nevada law. To exercise this right, if applicable, you or your authorized representative may contact us at us.privacy@boehringer-ingelheim.com.

 

O. Contact Us

If you have any questions about our Privacy Statement, want to receive this Privacy Statement in a different format, or want to exercise the data subject rights you have in connection with your Personal Data, you may contact us via email at us.privacy@boehringer-ingelheim.com, via webform by clicking here, or via mail or phone at the below contact information.

 

Boehringer Ingelheim USA Corporation 

900 Ridgebury Road

Ridgefield, CT 06877

Phone: 1-800-243-0127

 

Boehringer Ingelheim Animal Health USA Inc. 

3239 Satellite Blvd NW

Duluth, GA 30096

Phone: 1-800-325-9167