CALIFORNIA PRIVACY ADDENDUM

Date Last Updated: March 31, 2024

If you are a California resident, the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act, provides you with certain rights regarding your personal information. You may visit https://www.iqvia.com/about-us/privacy/privacy-policy for a broader discussion of our global privacy practices.

This California Privacy Notice (“Notice”) is provided on behalf of IQVIA, Inc. and other companies controlled by, or under common control with IQVIA, Inc. (collectively referred to as “IQVIA” in this Notice). It applies to information that IQVIA collects through its website (https://www.iqvia.com/), its mobile apps (available in the Apple Store or the Google Play Store), or through other IQVIA platforms and services (collectively, the “Services”). It also applies to information that IQVIA collects from its employees, job applicants, and independent contractors.

As discussed below and in our privacy policy, much of the personal information that IQVIA collects in the course of our business operations is not subject to the CCPA. Where we collect personal information as a Covered Entity or Business Associate under the Health Insurance Portability and Accountability Act (“HIPAA”), this information is not subject to the CCPA. Where we collect and maintain information in connection with clinical trials, this data is subject to clinical trial protocols and informed consents executed by individuals participating in these clinical trials and is not subject to the CCPA. In addition, IQVIA collects information that has been de-identified according to the HIPAA rules or other frameworks that is not “personal information” under the CCPA.

This Notice is also intended to serve as IQVIA’s Notice at Collection under the CCPA.

IQVIA Background

For more than sixty years, IQVIA has researched the use of medicines and health care and produced reports to help people understand real world practices. For more than thirty years, IQVIA has worked closely with sites and investigators in clinical research to help life science companies bring new medicines to patients. These IQVIA activities inform research and decision-making by people working in life sciences, payer organizations, provider organizations, patient and disease organizations, government and academia to improve patient outcomes, improve patient access to care, lower health care costs, reduce treatment disparities, advance safe practices and help various stakeholders improve health care throughout the world.

IQVIA uses healthcare information to advance human health globally by applying the discipline of human data science. IQVIA integrates the study of human science with breakthroughs in data science and technology to advance our understanding of human health. Through the application of human data science, we enable companies to reimagine and develop new approaches to clinical development, speed innovation and accelerate improvements in patient outcomes. To learn more about IQVIA’s use of human data science, visit our insights webpage (https://www.iqvia.com/insights/human-data-science) or visit the IQVIA Institute for Human Data Science (https://www.iqvia.com/insights/the-iqvia-institute).

If you are a Health Care Professional:

In IQVIA’s study of health care, IQVIA gathers information about health care professionals from a wide variety of sources, including health care organizations (e.g., physician practices, hospitals, clinics, pharmacies), Federal and state government organizations, payers, professional associations, web research, the organizations with which you are employed or affiliated, and directly from health care professionals. This information is used for various purposes, including regulatory compliance (e.g., transparency reporting, adverse event reporting, compliance with FDA Risk Minimization Action Plans (RiskMAPs) and corporate integrity agreements, delivery of drug safety warnings), sharing of information with health care professionals relating to FDA approved medicines, distribution of drug samples to requesting health care professionals with prescribing authority, research purposes (e.g., measuring and understanding treatment variability) and other commercial purposes. These uses are important to the efficient operation of the health care system, so please consider these uses carefully if you are considering exercising any of the rights described below.

If you are a Medical Doctor:

For several decades, IQVIA has worked closely with the American Medical Association (AMA) regarding use of information relating to medical doctors (MDs). IQVIA abides by the various options available from the AMA to provide MDs with choices available to manage the use of information. These options include:

• Contractual protections – restrictions required by the AMA regarding commercial use of physician identified information for all licensees of the AMA Physician Masterfile. IQVIA is a licensee of the AMA Physician Masterfile and has committed to these restrictions for many years.
• AMA Data Licensing Privacy Notice – Since 2002, the AMA Department of Database Licensing has used the AMA Data Licensing Privacy Notice (PDF) for the distribution of physician data. The AMA Data Licensing Privacy Notice addresses important information about AMA data collection, maintenance and licensing, AMA security procedures and the distribution of AMA physician data.
• AMA Do Not Contact – an option available to you to restrict unwanted correspondence. Obtain the "Do Not Contact" form on the AMA website (available at: https://www.ama-assn.org/practice-management/masterfile/ensuring-physician-database-privacy) and mail or fax the form per the instructions on the form.
• AMA Do Not Release Information – an option available to you to opt-out of having information about you routinely licensed by the AMA. Obtain the "Do Not Release Information" form on the AMA website (available at: https://www.ama-assn.org/practice-management/masterfile/ensuring-physician-database-privacy) and mail or fax the form per the instructions on the form.
• AMA Physician Data Restriction Program – In 2006, the AMA enhanced its privacy notice to include information on the AMA's Physician Data Restriction Program. The program empowers physicians by allowing them to restrict pharmaceutical sales representatives from accessing data about their prescribing activities.
• We also follow the AMA Best Practice Guidelines For Use of Prescribing Data by Industry (PDF). These guidelines reinforce the responsible use of data for the pharmaceutical industry. Obtain the Physician Data Restriction Form on the AMA website (available at: https://www.ama-assn.org/about/physician-professional-data/ama-physician-data-restriction-program) to either opt out of having prescribing data released or to register a complaint and report inappropriate behavior by pharmaceutical sales reps or companies.
• Exercising any of the rights described above will apply to all licensees of the AMA Physician Masterfile (most life science companies operating in the U.S. and most service providers supporting those companies, including IQVIA).

Collection of Personal Information

In certain situations where we collect personal information about you, such as when you visit or interact with our website or mobile apps or obtain services directly from IQVIA outside of a clinical research trial, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We may have collected the following categories of personal information over the past 12 months:

• Identifiers, such as your name, username, email address, or IP address.
• Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80, such as your name and address.
• Characteristics of protected classifications under California or federal law, such as your age.
• Commercial information, such as your purchase records (if any).
• Internet or other electronic network activity information, such as cookies, web logs, and information about how you use our website.
• Biometric information.
• Geolocation information.
• Audio, electronic, visual, thermal, olfactory, or similar information.
• Professional or employment-related information, such as your company name and address and any information that you provide in your job application with us.
• Education information, such as your college records.
• Inferences drawn from any of the information identified above, such as advertising profiles.
• Sensitive personal information, such as social security numbers, racial or ethnic origin information, and personal information collected and analyzed concerning a consumer’s health.

We collect the personal information listed above from the following sources:

• From you directly, when you make an account with us, subscribe to our website, apply for a job with us, or purchase or use one of our products or services.
• From your operating system and platforms.
• From public sources.
• From social networks, such as Facebook and Twitter, when you share our content on those platforms.
• Automatically from you when you visit our website.
• Health care organizations (e.g., physician practices, hospitals, clinics, pharmacies, payers).
• Federal and state government organizations.
• Professional associations or other organizations with which you are employed or affiliated.
• Data brokers and/or data aggregators.
• From other third-party sources, such as recruiters and employment websites.

We may collect and use personal information for the following purposes:

• To provide products, services, and information requested.
• Administrative purposes (such as to measure interest in and/or develop our services, ensure internal quality control, comply with regulatory requirements, prevent potentially prohibited or illegal activities, and enforce our terms of use).
• To market our products and Services.
• For research and development (including to create deidentified and aggregated information).
  
• Employment purposes (including to process your job application).
• Legal purposes (such as in relation to a government inquiry, a merger, or a sale).
• Any other purpose outlined in our Privacy Policy.

Disclosure, Sale, or Sharing of Personal Information

In the last 12 months, we may have disclosed, sold, or shared the following categories of personal information for our business or commercial purposes in relation to personal information subject to the CCPA:

• Identifiers.
• Categories of personal information described in subdivision (e) of California Civil Code Section 1798.80.
• Characteristics of protected classifications under California or federal law.
• Commercial information.
• Internet or other electronic network activity information.
• Biometric information.
• Geolocation information.
• Audio, electronic, visual, thermal, olfactory, and similar information.
• Professional or employment information.
• Education information.
• Inferences drawn from any of the information listed above.
• Sensitive personal information.

We may disclose, share, or sell your personal information to the following entities and for the following business and commercial purposes, in addition to providing our services and for the other purposes described in our general Privacy Policy:

Vendors and Service Providers: We may share any information we receive with vendors and service providers. IQVIA has executed appropriate contracts with the service providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Business Partners: IQVIA may share personal information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you.

Marketing, Interest-Based Advertising, and Third-Party Marketing: Through our Services, IQVIA may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-IQVIA related websites within their networks. If you prefer that we do not share your personal information with third party advertising partners, you may opt-out of such sharing at no cost by following the instructions in our privacy policy or through the process below.

To Process Your Employment Application. If you apply for a job with us, through our website or otherwise, we use the information you provide to process your job application. We may also supplement the information you provide with information that we collect from other sources, such as employment websites, recruiters, and social networks. We may share this information with our service providers who help us process your job application.

To Protect Us or Others (e.g., as Required by Law and Similar Disclosures): We may access, preserve, and disclose your personal information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce IQVIA policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

Your Rights

If we maintain personal information about you that is subject to CCPA, you may exercise certain rights in connection with this data if you are a California resident. As discussed above, much of the personal information or other information held by IQVIA is not subject to CCPA, including information obtained pursuant to the HIPAA Rules, in connection with clinical trials or when IQVIA receives or processes de-identified information.

Right to Know

California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months (“Right to Know”). Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• The categories of personal information that we have sold or disclosed for a business or commercial purpose and, for each category identified, the categories of third parties to which we sold or disclosed that particular category of personal information.
• Our business or commercial purposes for collecting or selling personal information.
• The categories of third parties with whom we share your personal information.
• The specific pieces of personal information we collected about you (i.e., a data portability request).

Right to Delete

California residents have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Correct

California residents have the right to request that we correct or amend the personal information we have on file (“Right to Correct”). Once we receive and confirm your verifiable consumer request, we will correct your personal information in our records with the updated information that you provide to us.

Right to Opt-Out of Sale or Sharing

The CCPA provides California residents with the right to opt-out of the “sale” or “sharing” of their personal information (“Right to Opt Out”). Some information that we disclose to third parties may constitute a “sale” or “sharing”, as those terms are defined in the CCPA. For example, information that we disclose about healthcare professionals to our business partners may constitute a sale. Additionally, information that we disclose to advertising networks for cross-context behavioral advertising may constitute “sharing”.

We do not sell identifiable information about individuals involved in clinical research studies or for individuals whose personal information we have received under the HIPAA Rules. We may sell in certain circumstances information that has been de-identified pursuant to HIPAA requirements or other applicable law, and this information is not personal information under the CCPA.

We do not knowingly “sell” or “share” personal information of minors under the age of 16.

Right to Limit the Use of Your Sensitive Personal Information

The CCPA provides California residents with the right to limit the use of their “sensitive personal information” to the purposes outlined in Cal. Code Regs. tit. 11, § 7027(m) of the CCPA regulations. In certain situations, we may process your personal information for purposes outside of what is permitted under this provision of the law, and you may have the right to limit such use.

Right to Nondiscrimination

The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights

If you are a California resident and wish to request for us to provide you with your rights under the CCPA, you may submit a request to us through the following ways:

• By webform through this link.
• By email at privacyofficer@iqvia.com
• By postal mail at
  IQVIA
  Attn: Global Chief Privacy Officer
  Plymouth Meeting, Pa 19462
• By telephone at 1-866-267-4479

If you submit a request by email, postal mail, or telephone, please include the following information with your request:

• Subject line: CCPA Request.
• A description of which CCPA right(s) you are exercising.
• Your full name.
• Your full address.
• Your telephone number used in connection with your interaction with IQVIA (if applicable).
• Your email address used in connection with your interaction with IQVIA (if applicable).
• Your email address where we can communicate with you regarding this CCPA request (if different from the email address described in the preceding bullet).
• The manner in which you participated in IQVIA activities or interacted with IQVIA (e.g., on-line web survey, 1-on-1 interview, written questionnaire).

Upon receiving a request from you, we will first verify your identity by matching the information you provide (including your name, email address, and phone number) with what we have on file for you. We may ask you for additional information to verify your identity or to comply with your request.

You may also designate an authorized agent to submit a request on your behalf. To designate an agent, please also send us a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. Please note that we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we are receiving a request.

If you have implemented an opt-out preference signal (sometimes known as a global privacy control) through your browser or device, we will treat that opt-out preference signal as a valid request of your Right to Opt Out. Once we recognize the opt-out preference signal on our Services, we will automatically apply your right to opt-out of sale and sharing to the browser or device through which we recognize the signal. The Services respond to opt-out preference signals in a frictionless manner (i.e., you do not need to take any additional steps for your opt-out preference signal to be recognized).

Data Subject Request Metrics

Under California law, IQVIA is required to make publicly available certain metrics regarding its responses to data subject requests (DSRs). Those metrics are provided in the table below. All metrics are for the calendar year 2023 and reflect requests made by California residents only.

Contact Us

If you have any questions about this Notice, you may reach out to us through the following means of contact:

• By email at privacyofficer@iqvia.com
• By postal mail at
  IQVIA
  Attn: Global Chief Privacy Officer
  Plymouth Meeting, Pa 19462
• By telephone at 1-866-267-4479