California Consumer Privacy Policy - Ironwood Pharmaceuticals

Ironwood Pharmaceuticals, Inc., (hereafter “Ironwood”) believes that as a California consumer, you have a right to know about your Personal Information (defined below) that Ironwood collects, uses, and discloses about you. But first please know that Ironwood does not sell your Personal Information. This California Consumer Privacy Policy (“CA Policy”) explains how Ironwood collects, uses, and discloses your Personal Information and answers specific questions that you may have regarding privacy and security.

This CA Policy is adopted to comply with the California Consumer Privacy Act (“CCPA”) and supplements and amends the information contained in Ironwood’s Privacy Policy with respect to California residents. It applies solely to individuals, visitors, users, and others who are natural persons and residents of the State of California. Any terms defined within the CCPA have the same meaning when utilizing within this CA Policy. Please read this carefully.

This Policy applies to the operation of this website and other applications under our control (including mobile applications) (collectively “Site”), that directly link to this policy as well as our collection of personal information through other channels. Ironwood’s product co-promotion and co-marketing partners may have additional privacy statements.

1. Your Rights Under the California Consumer Privacy Act (CCPA)

As a California consumer you have a number of rights under the CCPA including the following:

a. Your Right to Know:

You have a right to know:

(i) The categories of Personal Information Ironwood has collected about you;
(ii) The categories of places or sources where Ironwood got your Personal Information;
(iii) The business or commercial reason why Ironwood collects your Personal Information;
(iv) The categories of PI we disclose for a business purpose;
(v) The types of companies or people that we share or disclose your Personal Information with, and
(vi) The specific pieces of Personal Information that we collected about you during the prior 12 months.

b. How You Can Get This Information:

There are three ways you can contact us to get this information. We reserve the right to only respond to verifiable consumer requests.

(i) You can call us at 1-844-374-4793, or

(ii) You can submit a form to us by clicking on https://contactus.irwdpi.com/ and submitting your inquiry online.

(iii) You can send a letter to us at this address:

Ironwood Pharmaceuticals, Inc.
Attn: Privacy Officer
100 Summer Street
23rd Floor
Boston, MA 02110

(iv) When we receive your request, we will tell you within 10 calendar days that we received your request, and within 45 business days (and after we verify your request) we will let you know about the information you requested.

c. Your Right to Ask Ironwood to Delete Your Personal Information

You have the right to ask us to delete Personal Information that we have about you, subject to certain exceptions. Upon receipt of a confirmed verifiable consumer request, and as required by the CCPA, we will delete and direct any service providers to delete your personal information from our records.

(i) There are three ways you can ask us to delete your Personal Information:

a. You can call us at 1-844-374-4793, or

b. You can submit a webform to us by clicking on https://contactus.irwdpi.com/ and submitting your inquiry online.

c. You can send a letter to us at this address:

Ironwood Pharmaceuticals, Inc.
Attn: Privacy Officer
100 Summer Street
23rd Floor
Boston, MA 02110

d. When we receive your request, we will tell you within 10 calendar days that we received your request, and within 45 business days (and after we verify your request), we will respond to your request. If you ask Ironwood to delete your Personal Information, we will either respond that we will do so, or we will let you know that we will not due to a specified reason. For example, there may be a law that we have to follow that won’t permit us to delete your Personal Information.

A verifiable consumer request is one made by any individual who is:

the consumer who is the subject of the request,
a consumer on behalf of the consumer’s minor child, or
by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.

If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer when submitting a Request to Know or Delete.

In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

2. Categories of Personal Information Ironwood May Collect

Personal Information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. The Personal Information that we collect or have collected in the preceding 12 months about you may include one or more of the following:

Personal identifiers: This category includes names, addresses, telephone numbers, mobile numbers, email addresses, dates of birth, Social Security numbers, driver’s license or state identification numbers, bank account information, and other similar contact information and identifiers.
Protected classification information: This category includes characteristics of protected classifications under California or federal law.
Commercial information. This category includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information. This category includes without limitation: all activity on the Company’s information systems, such as internet browsing history, search history, intranet activity, email communications, social media postings, stored documents and emails, usernames and passwords; all activity on communications systems including phone calls, call logs, voice mails, text messages, chat logs, app use, mobile browsing and search history, mobile email communications, and other information regarding an Employee’s use of company-issued devices
Professional and Employment-related information and qualifications: This category includes, without limitation,
- data submitted with employment applications including salary history, employment history, employment recommendations, etc.
- background check and criminal history;
- work authorization
- fitness for duty data and reports
- performance and disciplinary records
- salary and bonus data, where permitted by law
- benefit plan enrollment, participation, and claims information
- leave of absence information including religious and family obligations, physical and mental health data concerning employee and his or her family members
Education information. This category includes education history.
Geolocation data. This category includes GPS location data from company-issued mobile devices and company-owned vehicles.
Biometric information: This category includes fingerprint scans and related information, certain wellness metrics facial recognition, and fingerprint or handpunch/hand-geometry data collected by a biometric time clock
Audio, electronic, visual, thermal, olfactory, or similar information.
Inferences drawn from the PI in the categories above

Information that can identify you. Things like your real name or an alias, your postal address, a unique personal identifier, an online identifier, your Internet Protocol address, your email address, account name, social security number, driver’s license number, and/or passport number;

Other information that can identify you like your signature, your physical characteristics or description, your cellphone or other telephone number, state identification card number, insurance policy number, your education, resume, transcript, your employment, employment history, bank account number, financial information, medical information, or health insurance information.

Additional personal information about you that we may collect including things like your birthday, your race and ethnicity, your citizenship, marital status, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.

We may also collect data about purchases you have made and your purchasing history

3. How Does Ironwood Get Your Personal Information?

In most cases, we collect Personal Information directly from you that you voluntarily submit to us. We will ask you for Personal Information when you interact with us, such as registering on our websites, using any interactive features or applications, signing up to receive a newsletter or a rebate, participating in a savings program, making a direct purchase, or contacting us to ask questions. We may collect additional information about you from things like public records, or from social media sites such as Facebook. In addition, we may get your personal information from companies that provide us with services or who help us with the services we provide to you. We treat this data as Personal Information only when it, or other data that is associated with it, can be used to identify you.

4. Why Does Ironwood Collect and Use Your Personal Information

Ironwood collects and uses your Personal Information for its business purposes, such as:

Responding to your requests for information, products, services, including managing your online accounts with us;
Providing you with general health information (such as information on certain health conditions) as well as information about our products and services;
Providing you with marketing communications and offers for products and services;
Delivering our products;
Running promotional programs, such as sweepstakes, rewards, and rebate programs;
To determine if you are eligible for certain products, services, or programs (such as patient savings programs);
If you have a business or professional relationship with Ironwood, to develop our business relationship with you;
If you apply for a job via our career center, to consider you for employment;
For our research and development efforts, like clinical studies in which you may be interested;
To monitor and analyze our business operations and website and other applications usage;
To make your data anonymous so that it is no longer Personal Information
For product safety reasons such as side effect (adverse event) reporting, product complaint reporting, or to communicate product safety information to you; and/or:
To verify such things as professional status, identity and specialty when providing information, communications or products/and or services to doctors and other healthcare professionals, and
For other everyday business purposes, such as payment processing and financial account management, product development, contract management, website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance.

5. Who do we Share Your Personal Information With?

As a reminder please know that Ironwood does not sell your Personal Information. In addition, we do not share or distribute your Personal Information with any other company for their marketing purposes. Ironwood will share your Personal Information only in compliance with applicable laws and regulations. For example, we may share or have shared your Personal Information with other people and other companies as follows:

We may share your Personal Information with your consent or as you direct. For example, we may share data with your doctor as part of programs in which you agree to participate.
We may share your Personal Information with our affiliated companies, product co-promotion and co-marketing partners, which may only use your Personal Information for the purposes as we have agreed to.
We may share your Personal Information with companies that provide services to us like health insurance companies or payroll companies. These companies are bound by law or contract to protect your Personal Information and only use your Personal Information the way we tell them to.
We may also disclose your Personal Information where needed to sell or transfer business assets, to investigate legal issues, enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions.
We may also disclose your Personal Information if required by law, such as in response to a subpoena, or to comply with requirements of law enforcement agencies and courts in the United States and other countries where we operate.
Please note that we may also disclose data about you that is called “de-identified” or “aggregated” data. This type of information does not identify who you are so it is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers. These reports do not contain any data that would let somebody contact, locate, or identify you.

6. Non-Discrimination

If you make a request to Ironwood to know your Personal Information or you request that Ironwood delete your Personal Information, Ironwood will respond to your request, but we will never discriminate against you for making such a request or because you exercised your rights under the California Consumer Privacy Act. As a California consumer you are entitled under California law to make such requests and we will not discriminate against you if you do. If you make a request under the California Consumer Privacy Act Ironwood will not discriminate against you in any way including that we will not deny you goods or services, charge you different prices or rates for goods or services, deny you discounts or other benefits or impose penalties on you, provide you with or suggest that you will receive a different level or quality of goods or services.

7. Authorized Agents

If you would like, you can permit someone to submit a request to know your Personal Information that Ironwood has collected or a request to delete your Personal Information that Ironwood has collected. This person is called an Authorized Agent. If an Authorized Agent sends us a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you. If that person doesn’t provide us with written proof, we will deny their request so that we can protect your Personal Information.

8. Children’s Privacy

Ironwood websites and applications are not intended to attract children, and we do not knowingly collect any Personal Information of anyone under the age of 16. If you believe your child is using our website, please contact us online at www.ironwoodpharma.com/contact-us by clicking on the “Privacy or personal data inquiries pertaining to Ironwood’s privacy policy” link, so we can investigate and delete any inappropriate data.

We do not sell your PI and do not have actual knowledge that we have sold personal information of minors under age 16.

9. Ironwood’s General Privacy Policy

For more information about Ironwood’s Privacy Policy, please click this link.

Updated: September 14, 2020