Healthcare Providers Privacy Notice
Effective Date: August 28, 2025
Arrowhead Pharmaceuticals Ireland Limited (“Arrowhead”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Notice for Healthcare Professionals (“HCPs”, “you”, or “your”) (“Privacy Notice”) describes our practices regarding the collection, use, and disclosure of your Personal Information (as defined below) when you visit our website (lowertriglycerides.eu) (the “Website”), and interact with us offline. This Privacy Notice also describes your privacy rights in connection with Personal Information we collect about you. We are the controller of Personal Information processed in the context of this Privacy Notice.
This Privacy Notice will not apply to Personal Information collected and processed by us:
- should you participate in a clinical trial that we sponsor;
- if you are an individual other than a HCP;
- should you apply for a job with us; or
- in the course of your employment with us.
By accessing our Website, you agree to our Terms of Use.
For purposes of this Privacy Notice, “Personal Information” means information relating to an identified or identifiable individual. The term does not include aggregated information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Personal Information We Collect
We collect the following categories of Personal Information:
- Personal identifiers: name, residential and business address, home and business telephone number(s), email address(es), and IP address;
- Commercial and financial information: payment information, account information, and details of any financial relationship with us, information about prescriptions written, inquires or requests for assistance regarding our products or services;
- Professional or employment-related information: name of your practice, professional designation, medical specialty, licensing and disbarment status, publications and information about public speeches, and additional Personal Information you provide in your curriculum vitae or other similar documents or communications;
- Education information: academic background and credentials;
- Internet or electronic network information: your browser type, operating system, domain names visited, click activity, referring websites, the date and time and length of visit of your visit to our Website or other websites or mobile applications;
- Audio and visual information: recordings of calls made to our information and support lines; audio and visual recordings of presentations given by you; and
- Inferences drawn from any above data to create profile reflecting an HCP’s interest as they relate to the types of products and educational offerings provided by Arrowhead.
Retention Periods
We retain the categories of Personal Information we collect for as long as we need for a legitimate purpose. The criteria used to determine the retention periods include: (i) how long the Personal Information is needed to provide / receive the services and operate the business; (ii) the type of Personal Information collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the Personal Information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation or data that must be retained for the purposes of court orders, regulatory investigations, or legal proceedings).
Sources From Which We Collect Personal Information
We collect Personal Information from you when you: (i) attend or register to attend an event sponsored by us; (ii) participate in one of our advisory boards or speak at an event on our behalf; (iii) request information from us about our products or services; (iv) apply for a grant, donation or sponsorship; (v) respond to one of our surveys; or (vi) otherwise interact with us including, via the Website. We may also collect your Personal Information from patients, other HCPs or medical professionals, dispensing entities, from data brokers specializing in HCP data, and from publicly available sources.
Automated Decision-Making / Profiling
We do not process your Personal Information on the basis of any automated decision-making including profiling.
Cookies and Other Technologies
We use “cookies” and other similar technologies, some of which are essential for our Website to function. Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website, and for digital advertising. For non-essential cookies (including analytics and advertising cookies), we will only use these if you provide your opt-in consent through our cookie banner or preference tool. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.
Additionally, we use Google Analytics (only where you have consented to the use of non-essential cookies) to evaluate the use of our Website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects Personal Information, review Google’s Privacy Policy.
How We Use The Personal Information We Collect
We have set out below, a description of the ways we use your Personal Information (referred to as “processing purposes” below), and, we explain which of the legal bases we rely on for such processing purposes.
| Categories of Personal Information | Processing Purposes | Legal Basis |
|---|---|---|
| Where you register to attend and/or attend a sponsored event: | ||
| Personal identifiers; Audio and visual information; travel and accommodation information | The administration and conduct of the relevant event, including to respond to your enquiries and communicate with you about the event which may involve the recording of calls. | Where we have a legitimate interest to ensure the effective administration and conduct of the relevant event. |
| Personal identifiers; Audio and visual information | Enabling the creation, distribution, broadcast or other use of any recordings made during the event | Where we have a legitimate interest to promote the event, to leverage the learnings from the event, and to more generally operate and improve our business |
| Personal identifiers |
To invite you to future events and to send you other promotional information about our
products (where permitted by law). You can withdraw your consent, if provided, at any
time. If you wish to stop receiving marketing or market research communications from
us you can unsubscribe via the link at the bottom of the relevant e-mail or contact us
using the contact details below. Where required by applicable law, when you voluntarily provide your Personal Information via an online form on the Website, we will send you a confirmation email requiring you to confirm your agreement to receive marketing communications (double opt-in) and only after confirmation will you begin receiving marketing communications. | If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. Where required by applicable law, we use a double opt-in mechanism (i.e., in the sign-up form and in the follow-up email that verifies consent) to ensure valid consent. In other instances, we will send marketing communications to you where this is in our legitimate interest. |
| Personal identifiers | The storage of your Personal Information in databases for use when sending invites to future events. | Where we have a legitimate interest to manage our business and the conduct of future events. |
| All categories of Personal Information | Compliance with and satisfaction of legal obligations and regulatory requirements for purposes of financial reporting / public disclosure obligations in relation to agreements with and/or payments and benefits to HCPs and healthcare organizations. | To comply with a legal obligation. Where we have a legitimate interest to comply with applicable transparency reporting obligations (including, those in the United States). |
| Where you participate in an Arrowhead advisory board: | ||
| Personal identifiers; Professional or employment information; Education information; Audio and visual information | The administration and conduct of the relevant advisory board, including to respond to your enquiries and communicate with you about the advisory board which may involve the recording of calls. | Where we have a legitimate interest to ensure the effective administration and conduct of the advisory board. |
| Personal identifiers; Audio and visual information | Enabling the creation, distribution, broadcast or other use of any recordings made during the advisory board | Where we have a legitimate interest to leverage the learnings from the advisory board, and to more generally operate and improve our business |
| Personal identifiers; Professional or employment information; Education information | The storage of your Personal Information in databases for use when selecting HCPs for future advisory boards. | Where we have a legitimate interest to manage our business and the conduct of future advisory boards. |
| All categories of Personal Information | Compliance with and satisfaction of legal obligations and regulatory requirements in the context of safety data reporting activities, and for purposes of financial reporting / public disclosure obligations in relation to agreements with and/or payments and benefits to HCPs and healthcare organisations. | To comply with a legal obligation. Where we have a legitimate interest to comply with applicable transparency reporting obligations (including, those in the United States). |
| Where you are engaged to speak on our behalf: | ||
| Personal identifiers; Professional or employment information; Education information; Audio and visual information | The administration and conduct of the relevant event, including to respond to your enquiries and communicate with you about the event which may involve the recording of calls or the event. | Where we have a legitimate interest to ensure the effective administration and conduct of the relevant event. |
| Personal identifiers; Audio and visual information | Enabling the creation, distribution, broadcast or other use of any recordings made during the event. | Where we have a legitimate interest to promote the event, to leverage the learnings from the event, and to more generally operate and improve our business. |
| Personal identifiers; Commercial and financial information; Professional or employment information; Education information | Meeting our contractual obligations under the speaker agreement with you including, to pay you for your speaking services. | Where necessary for performance of a contract. |
| Personal identifiers; Professional or employment information; Education information | The storage of your Personal Information in databases for use when selecting speakers for future events. | Where we have a legitimate interest to manage our business and the conduct of future events. |
| All categories of Personal Information | Compliance with and satisfaction of legal obligations and regulatory requirements for purposes of financial reporting / public disclosure obligations in relation to agreements with and/or payments and benefits to HCPs and healthcare organisations. | To comply with a legal obligation. Where we have a legitimate interest to comply with applicable transparency reporting obligations (including, those in the United States). |
| When you contact us or we communicate with you: | ||
| Personal identifiers; Audio and visual information | To respond to your enquiries and communicate with you including, where these relate to, for example, requests for funding, grants, early access programs. | Where we have a legitimate interest to manage our business, and to process and respond to your communications. |
| Audio and visual information | To make and use recordings of calls made to our information and support lines. | Where we have a legitimate interest to manage our business, and to process and respond to your communications. |
| Personal identifiers; Commercial and financial information; Professional or employment information | To send you promotional information about our products or otherwise engage in advertising and marketing (where permitted by law). If you wish to stop receiving marketing or market research communications from us you can unsubscribe via the link at the bottom of the relevant e-mail or contact us using the contact details below. | If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. Where required by applicable law, we use a double opt-in mechanism (i.e., in the sign-up form and in the follow-up email that verifies consent) to ensure valid consent. In other instances, we will send marketing communications to you where this is in our legitimate interest. |
You have a right to object to the processing of your Personal Information where that processing is carried out for our legitimate interests. Please note however, that we may not be able to fulfil such requests in all instances.
Disclosure of Your Personal Information
We may disclose Personal Information to the following third parties in connection with the processing purposes:
- our affiliates;
- service providers that manage HCP information and provide patient support services, provide access to audio or video recordings, facilitate email communications, provide security services and cloud-based data storage, host our Website and assist with other IT-related functions, advertise and market our products and services (including educational offerings), provide market research and analytics information, and provide legal and accounting services;
- third parties we consult and engage as part of our clinical research and compliance activities, such as research partners, ethics committees, and professional advisors, and clinical research monitors and research organizations;
- to third parties as required or permitted by law to comply with a court order, regulatory request, or other legal process or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities;
- third parties to help detect and protect against fraud or data security vulnerabilities; and
- third parties in the event of an actual or contemplated sale, merger, reorganization of our entity or other restructuring.
Security
We take reasonable steps, consistent with generally accepted industry standards, including technical, administrative and physical safeguards to protect Personal Information we process from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, no system is fully secure and we cannot guarantee the security of your Personal Information.
International Transfers of Personal Information
All Personal Information collected (including via the Website and from other sources described in this Privacy Notice) may be processed in the U.S. where our corporate group headquarters are located. Where we disclose Personal Information originating in the EEA/UK to a third party (e.g., a service provider) located outside of the EEA/UK we will as deemed necessary, enter into an appropriate data transfer agreement (e.g., the EU Standard Contractual Clauses and, for the UK, the International Data Transfer Agreement or UK Addendum to the Standard Contractual Clauses) with that third party, seek to rely on the third party’s Binding Corporate Rules or otherwise make the transfer in reliance on a derogation under EEA/UK data protection laws (e.g., where the transfer is necessary for the defense of legal claims). Intra-group transfers of Personal Information are made in reliance on an appropriate data transfer agreement (e.g., the EU Standard Contractual Clauses and, for the UK, the International Data Transfer Agreement or UK Addendum to the Standard Contractual Clauses). If you would like further information in relation to, or a copy of, the relevant safeguards, you can contact us using the details set out below.
Children’s Privacy
The Website and other HCP-related data processing activities are not directed to minors under the age of 16. We do not have actual knowledge that we collect Personal Information from minors, including those under the age of 16.
Third Party Links
Our Website may contain social media buttons or links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on those social media platforms or third-party websites.
Your Data Privacy Rights
You have the following data privacy rights which may be subject to limitations / restrictions:
- The right to request access to your Personal Information;
- The right to request that your Personal Information be corrected or deleted;
- The right to request that we restrict our processing of your Personal Information;
- The right to object to the processing of your Personal Information where it is carried out (i) for our legitimate interests – unless we can demonstrate compelling legitimate grounds for the processing; and/or (ii) for direct marketing purposes;
- The right to withdraw consent to the processing of your Personal Information; and
- The right to request that Personal Information be provided to you or a third-party in a machine-readable format.
Please contact us using the details set out below in case you wish to exercise any of the above rights.
You also have the right to file a complaint with the competent data protection authority if you have any reason to believe we have not properly handled your Personal Information or have not respected your rights.
Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at [email protected].
Changes to Our Privacy Notice
We may revise or supplement this Privacy Policy from time to time. If we make any substantial changes in the way we use or share your Personal Information, we will notify you by posting a notice on our Website prior to the change becoming effective. We encourage you to refer to this Privacy Policy on an ongoing basis, so you understand our current privacy practices.
Contact Us
Questions, comments and requests regarding this Privacy Notice are welcomed, including requests relating to exercising any of your data privacy rights. Please use the following contact details: [email protected]
If you reside in the EEA, please contact our EEA Data Protection Representative using the following contact details:
Kaleidoscope Data Privacy Consultants Limited
The Black Church, St Mary’s Place, Dublin DO7 P4AX
Call: +353 1531 4464
Email: [email protected]
If you reside in the UK, contact details for our UK Data Protection Representative are as follows:
Kaleidoscope Consultants Limited
East Side, Kings Cross, London N1C 4AX
Call: +44 (0)20 3637 1111
Email: [email protected]