Privacy Policy

1. Introduction

Wockhardt Suisse USA LLC ("Company," "we," "us," or "our"), a Delaware limited liability company, is a wholly owned subsidiary of Wockhardt Suisse USA Holding Corporation, which is a wholly owned subsidiary of Wockhardt Suisse AG, which in turn is a wholly owned subsidiary of Wockhardt Bio AG, a subsidiary of Wockhardt Limited. We respect your privacy and are committed to protecting the personal information collected through our websites and digital services.

This Privacy Policy describes how we collect, use, disclose, store, transfer, and protect personal information when you visit, access, register for, or otherwise interact with our United States healthcare professional website, ‘https://www.zaynich.com/’ (the "Website").

The Website is intended for healthcare professionals ("HCPs") located in the United States who are seeking information about Zaynich, its approved uses, and related scientific, medical, or pharmaceutical information.

This Privacy Policy applies to personal information processed through the Website, including information submitted during HCP registration, professional credential verification, account access, medical information inquiries, and other Website interactions.

This Privacy Policy should be read together with any additional privacy notices provided at the point of collection, including notices applicable to specific services or U.S. state privacy requirements.

By using the Website, you acknowledge that this Privacy Policy has been made available to you. Where applicable law requires your consent for particular processing activities, we will seek that consent separately.

2. Identity of the Data Controller

For the personal information covered by this Privacy Policy, the entity responsible for determining the purposes and means of processing is:

Registered Address:

Wockhardt Suisse USA LLC
1200 Morris Turnpike, Suite 3005
Short Hills, New Jersey 07078
Country: United States

Privacy Contact: dpo.india@wockhardt.com

Wockhardt Suisse USA LLC is a wholly owned subsidiary of Wockhardt Suisse USA Holding Corporation, which is a wholly owned subsidiary of Wockhardt Suisse AG, which in turn is a wholly owned subsidiary of Wockhardt Bio AG, a subsidiary of Wockhardt Limited. Wockhardt Suisse USA LLC is responsible for the processing described in this Privacy Policy. We may engage these affiliated and subsidiaries companies and authorized service providers to perform operational, administrative, technical, medical, regulatory, and support activities on our behalf.

Where an affiliate and subsidiary independently determines the purposes and means of processing personal information, or jointly determines those purposes and means with us, the relevant responsibilities and additional information will be communicated as required by applicable law.

3. Scope and Intended Audience

The Website is intended for healthcare professionals located in the United States, including physicians, pharmacists, and other qualified healthcare professionals authorized to access the information made available through the Website.

Certain Website content and services may require professional verification and successful registration before access is granted.

The Website is not intended to provide individualized medical advice, establish a patient–healthcare professional relationship, or replace independent professional medical judgment.

The Website is not directed toward children or individuals under 18 years of age, and we do not knowingly collect personal information directly from children through HCP registration services.

If we become aware that personal information has been collected from a child inappropriately, we will take reasonable steps to address the matter in accordance with applicable law.

4. Categories of Personal Information We Collect

We may collect the following categories of personal information, depending on your interactions with the Website and the services you use.

4.1 Personal Identification and Contact Information

• Full name
• Professional title
• Business email address
• Business telephone number
• Professional mailing address
• Country, state, and other location information
• Other information voluntarily provided in communications with us

4.2 Professional and Healthcare Credential Information

• Healthcare profession and designation
• Medical or professional specialty
• National Provider Identifier (NPI), where applicable
• Professional license details
• State of professional practice
• Healthcare institution or organizational affiliation
• Professional qualification and verification status
• Other information reasonably required to confirm healthcare professional eligibility

4.3 HCP Registration and Account Information

• Registration details
• Username or account identifier
• Authentication credentials or protected authentication records
• Account verification status
• Login activity
• Account preferences
• Access permissions
• Records of relevant account-related communications

4.4 Technical and Website Usage Information

When you access the Website, certain information may be collected automatically, including:

• Internet Protocol (IP) address
• Browser type and version
• Device type and operating system
• Pages viewed and Website navigation activity
• Date and time of access
• Session and authentication information
• Cookie identifiers and similar online identifiers
• Referring websites or access sources
• Technical error and security logs

4.5 Communications and Inquiry Information

If you contact us through the Website or associated communication channels, we may collect:

• Your name and contact information
• The nature and content of your inquiry
• Product-related or scientific questions
• Relevant professional information
• Information required to respond to your request
• Records of correspondence and follow-up communications

4.6 Product Safety and Medical Information

Where an HCP submits an adverse-event report, product quality complaint, medical inquiry, or other safety-related communication, we may process information reasonably necessary to document, assess, investigate, respond to, and report the matter.

Such information may include personal information relating to the reporting HCP and, where applicable, information concerning a patient or another individual.

We request that HCPs avoid providing directly identifiable patient information unless necessary for the relevant safety or medical reporting purpose and permitted by applicable law.

5. Sources of Personal Information

We limit the collection, use, retention, and disclosure of personal information to what is reasonably necessary and proportionate for the purposes described in this Privacy Policy or for another compatible purpose disclosed to you. We do not collect additional categories of personal information or use personal information for materially different purposes without providing any notice or obtaining any consent required by applicable law.

We may obtain personal information from:

1. You directly: Information entered during registration, account management, inquiries, or other interactions.
2. Professional verification sources: Publicly available professional registries, licensing authorities, credential databases, and authorized HCP verification providers.
3. Our corporate affiliates and subsidiaries : Information lawfully shared within our corporate group for relevant operational, regulatory, or business purposes.
4. Authorized service providers: Information received from vendors supporting Website hosting, registration, verification, technical services, communications, and security.
5. Automated technologies: Information generated through cookies, server logs, authentication systems, and similar technologies.

Where required by applicable law, additional information concerning third-party sources will be provided.

6. Purposes for Which We Use Personal Information

We may process personal information for the following purposes:

6.1 HCP Verification and Access Management

To verify professional eligibility, validate credentials, establish user accounts, authenticate registered HCPs, and administer access to professional product information.

6.2 Providing Pharmaceutical and Scientific Information

To provide access to product-related information, clinical and scientific materials, prescribing information, approved labeling, educational resources, and other relevant content appropriate for healthcare professionals.

6.3 Responding to Medical and Scientific Inquiries

To receive, assess, respond to, and maintain appropriate records of medical information requests, product questions, and other professional communications.

6.4 Pharmacovigilance and Regulatory Compliance

To identify, evaluate, document, investigate, and report adverse events, product quality complaints, and other information where necessary to meet applicable safety, quality, and regulatory obligations.

6.5 Website Administration and Security

To maintain Website performance, manage accounts, detect unauthorized access, prevent misuse, maintain security, investigate incidents, and support technical operations.

6.6 Website Analytics and Improvement

To understand Website usage, evaluate performance, improve functionality, and enhance the relevance and accessibility of Website content.

6.7 Professional Communications and Marketing

To send permitted product updates, scientific information, professional communications, event invitations, or other promotional materials, subject to applicable legal requirements and available preferences.

You may opt out of receiving promotional emails using the unsubscribe mechanism provided in the relevant communication.

6.8 Legal and Business Purposes

To comply with applicable laws and regulations, respond to lawful requests from competent authorities, establish or defend legal claims, maintain appropriate business records, and support legitimate corporate operations.

We will not use personal information for materially incompatible purposes without providing additional notice or obtaining consent where required by applicable law.

7. Cookies and Similar Technologies

The Website may use cookies and similar technologies to support its operation and understand how users interact with its content.

Depending on the technologies deployed, these may include:

Strictly Necessary Cookies

Used to support essential Website functions, including authentication, account security, access management, and session maintenance.

Functional Cookies

Used to remember preferences and provide enhanced Website functionality.

Analytics Cookies

Used to assess Website performance, visitor interactions, and the effectiveness of digital content.

Advertising or Marketing Technologies

Where used, these technologies may support measurement of promotional activities or delivery of relevant communications.

Certain technologies may be operated by third-party providers that collect or receive information about Website interactions.

Where required by applicable law, we will obtain consent, provide opt-out mechanisms, or recognize applicable privacy preference signals before or in connection with the use of relevant technologies.

You can adjust preferences via your browser settings.

8. Disclosure and Sharing of Personal Information

We may disclose personal information to the following categories of recipients, where necessary and permitted by applicable law:

8.1 Corporate affiliates and subsidiaries

Companies within our corporate group, including Wockhardt Suisse USA Holding Corporation, Wockhardt Suisse AG, Wockhardt Bio AG, and Wockhardt Limited, for authorized activities such as information technology, compliance, regulatory support, pharmacovigilance, and operational administration.

8.2 Technology and Service Providers

Third parties providing Website hosting, cloud infrastructure, security, HCP verification, customer relationship management, communication delivery, analytics, and related services.

8.3 Medical, Safety, and Regulatory Service Providers

Authorized organizations assisting us with medical inquiries, pharmacovigilance, product safety, quality assurance, and legally required reporting.

8.4 Regulatory and Government Authorities

Regulatory agencies, courts, law enforcement, or other competent authorities where disclosure is required or otherwise permitted by law.

8.5 Professional Advisers and Business Transactions

Legal advisers, auditors, consultants, and relevant parties involved in proposed or completed corporate reorganizations, mergers, acquisitions, or other business transactions, subject to appropriate protections.

We require service providers processing personal information on our behalf to comply with applicable contractual, confidentiality, security, and data protection obligations.

We do not permit service providers to use personal information for unrelated purposes except where permitted by applicable agreements and law.

Sale and Sharing of Personal Information

We do not sell personal information for monetary or other valuable consideration, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under applicable U.S. state privacy laws.

9. International Transfers of Personal Information

As a U.S. company operating within an international pharmaceutical group, we may process or disclose personal information across national borders to our affiliates and subsidiaries and service providers Such processing may involve our authorized affiliates and subsidiaries, hosting providers, technology service providers, medical information personnel, or regulatory support teams.

Data protection laws in the countries where information is processed may differ from those applicable in your state or country of residence.

Where required, we implement appropriate measures to protect personal information transferred internationally, which may include contractual data protection provisions, appropriate access controls, security safeguards, and recognized international transfer mechanisms.

For any such cross-border transfer, we use appropriate safeguards, which may include intra-group data protection agreements, contractual confidentiality and security obligations, and other measures reasonably designed to protect personal information consistent with this Privacy Policy

For additional information concerning relevant international transfers, please contact us using the details in Section 18.

10. Retention of Personal Information

We retain personal information for no longer than reasonably necessary to fulfill the purposes for which it was collected, subject to applicable legal, regulatory, safety, and recordkeeping requirements.

The retention period may vary depending on the type of information and its purpose.

Where personal information is no longer required, we will delete, anonymize, or otherwise securely dispose of it, unless continued retention is legally required or otherwise permitted.

11. Information Security

We implement reasonable and appropriate technical, organizational, and administrative measures designed to protect personal information against unauthorized access, loss, alteration, misuse, destruction, or disclosure.

Depending on the systems and information involved, these measures may include:

• Role-based access controls
• User authentication and account security measures
• Encryption or other appropriate technical protections
• Security monitoring and incident response procedures
• Confidentiality obligations
• Vendor security assessments
• Personnel training and security awareness procedures

No electronic transmission or storage system can be guaranteed to be completely secure.

We periodically review relevant security measures and update them as appropriate to the nature of our operations and the information processed.

12. Your Privacy Rights and Choices

Depending on your state of residence, the nature of our processing activities, and applicable privacy laws, you may have certain rights relating to your personal information.

These may include:

Right to Access

Request confirmation of whether we process your personal information and obtain information about, or access to, that information.

Right to Correction

Request correction of inaccurate personal information, subject to applicable requirements and exceptions.

Right to Deletion

Request deletion of qualifying personal information, subject to applicable legal and regulatory retention obligations.

Right to Data Portability

Request a copy of eligible personal information in a portable format where required by law.

Right to Opt Out

Where applicable, opt out of the sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, or certain profiling activities.

Right to Limit Certain Processing

Exercise applicable rights concerning sensitive personal information or other processing subject to statutory restrictions.

Right to Withdraw Consent

Where processing is based on consent, withdraw that consent using the available mechanism, subject to applicable law.

Right to Appeal

Appeal a refusal of a privacy-rights request where required by applicable state law.

Non-Discrimination

Where applicable law provides protection against discrimination for exercising privacy rights, we will respect those protections.

How to Exercise Your Rights

You may submit a privacy-related request through:

Email: dpo.india@wockhardt.com

An authorized agent may submit a request on your behalf where permitted by applicable law. We may require evidence that you authorized the agent to act for you and may also ask you to verify your identity or confirm the request directly, unless the agent holds a valid power of attorney or applicable law provides otherwise.

We will respond within the timeframes required by applicable law and explain any applicable reasons for declining or limiting a request.

Certain information may be retained notwithstanding a deletion request where necessary to comply with legal obligations, maintain product safety records, protect security, or fulfill other permitted purposes.

13. Additional Privacy Disclosures for U.S. Residents

Residents of certain U.S. states may be entitled to additional information or rights under applicable state privacy laws.

The following provisions apply only to the extent that the relevant state law applies to our business and the processing of your information.

13.1 California Residents

If the California Consumer Privacy Act, as amended, applies to our processing of your personal information, California residents may have rights to know, access, correct, delete, and obtain certain information, as well as applicable rights to opt out of the sale or sharing of personal information and limit qualifying uses or disclosures of sensitive personal information.

We will provide applicable California notices at or before relevant collection points and comply with statutory requirements concerning authorized agents, request verification, consumer choices, and nondiscrimination. You may submit requests or manage your choices by contacting us using the methods outlined in Section 18.

13.2 Residents of Other States With Applicable Privacy Laws

Where applicable state privacy laws grant rights to residents of Colorado, Connecticut, Virginia, and other jurisdictions, we will provide the applicable disclosures and mechanisms for exercising those rights.

These may include rights to access, correct, delete, or obtain personal information, opt out of certain processing, and appeal decisions concerning rights requests.

The rights available to you depend on the relevant law, including its jurisdictional thresholds, definitions, exceptions, and applicability to personal information processed in a professional capacity.

For information about available privacy rights and request procedures, please contact us using the details in Section 18

14. Medical Inquiries, Adverse Events, and Pharmacovigilance

As part of our responsibilities relating to pharmaceutical product safety and regulatory compliance, we may receive or process information about suspected adverse events, product quality complaints, medication-related issues, or other safety matters.

Such information may be submitted by healthcare professionals or received through authorized channels.

We may collect and use relevant information for purposes including:

• Assessing and documenting reported events
• Conducting appropriate medical or safety follow-up
• Evaluating potential product safety concerns
• Maintaining legally required safety records
• Submitting reports to relevant regulatory authorities
• Complying with pharmacovigilance and product safety requirements

Where required and permitted by law, relevant information may be shared with authorized affiliates and subsidiaries, pharmacovigilance service providers, regulatory authorities, and other appropriate recipients.

Patient and reporter information will be handled in accordance with applicable privacy, confidentiality, and regulatory requirements.

We may be required to retain certain pharmacovigilance records even after an HCP account is closed or a privacy deletion request is submitted.

Healthcare professionals should use the designated product safety reporting channels and avoid submitting unnecessary patient identifiers through general Website contact forms.

15. Marketing and Professional Communications

We may communicate with registered healthcare professionals regarding relevant product information, scientific and educational materials, professional events, Website updates, and other permitted communications.

Where required by law, we will obtain appropriate consent before sending promotional communications or undertaking relevant marketing activities.

You may unsubscribe from promotional email communications using the unsubscribe link provided in those messages

Opting out of promotional communications does not necessarily prevent us from sending essential account, security, requested medical information, or legally required regulatory communications.

We will maintain applicable communication preferences and suppression records to respect your choices.

16. Third-Party Websites and Services

The Website may contain links to websites, platforms, professional resources, or services operated by third parties.

These third-party websites and services are governed by their own privacy notices and practices.

We encourage you to review the relevant privacy information before providing personal information to third parties.

This Privacy Policy does not govern independent processing activities conducted by third parties outside our control.

17. Changes to This Privacy Policy

We may revise this Privacy Policy periodically to reflect changes in our Website, information practices, legal requirements, or business operations.

When changes are made, we will update the "Last Updated" date displayed at the beginning of this Privacy Policy.

Where required by law, we will provide additional notice or obtain relevant consent before implementing material changes to the processing of personal information.

We encourage you to review this Privacy Policy periodically.

18. Contact Us

For questions, concerns, privacy-rights requests, complaints or inquiries regarding this Privacy Policy or our processing of personal information, please contact:

Privacy Office:

Wockhardt Suisse USA LLC
1200 Morris Turnpike, Suite 3005
Short Hills, New Jersey 07078
USA.

Email: dpo.india@wockhardt.com