Notice at Collection for Candidates & Employees
We may collect the following categories of personal information about you in connection with your employment or application for employment: identifiers, demographic information, professional and employment-related information and qualifications, education information, sensitive personal information (including Social Security number, race, ethnic origin), and inferences drawn from the above-listed categories of personal information. We also may collect these additional categories of personal information during the course of your employment: financial information, Internet or other electronic network activity information (for example, when you use company-owned IT resources) geolocation data (such as when you use a company-owned vehicle or device), and audio, electronic, visual, thermal, olfactory, or similar information (such as your photograph).
Ironwood collects and uses your personal information, including your sensitive personal information, solely in connection with administering the employment relationship (such as providing benefits, payroll, performance reviews, permitting access to Ironwood facilities and resources) or evaluating your application for employment (such as screening applicants, determining employment eligibility, conducting interviews, and negotiating an employment offer). Ironwood does not “sell” or “share” your personal information, as those terms are defined by the California Privacy Law.
We will retain your personal information for as long as necessary to satisfy the purposes for which we collected it, including to evaluate your candidacy or administer the employment relationships, as well as to comply with any applicable legal, accounting, or reporting requirements; to establish, exercise, or defend legal claims; or for our legitimate purposes. Requests to delete your personal information are subject to these obligations and restrictions.
Applicants should know that, to submit your application, you may be interacting with us through a third-party application platform, such as Greenhouse, ADP, EBI or LinkedIn, which Ironwood does not control. Before proceeding, you should review the privacy policies published by these third parties to understand how they will handle your personal information. information.
Notice at Collection for Website Visitors and Other Consumers
We may collect the following categories of personal information from you in connection with your use of our website or other interaction with our us and our products: identifiers, demographic information, commercial information, internet or other electronic network activity information (e.g., internet browsing history, search history, intranet activity, email communications, social media postings), and audio, electronic, visual or similar information (such as calls that are recorded for quality assurance purposes), and inferences drawn from the PI in the categories above.
Ironwood does not “sell” or “share” your personal information, as those terms are defined by the California Privacy Law.
We will retain your personal information for as long as needed to satisfy the purposes for which we collected it, to comply with any applicable legal, accounting, or reporting requirements; to establish, exercise, or defend legal claims; or for our legitimate purposes.
This Policy applies to the operation of our website, www.ironwoodpharma.com, and other applications under our control (including mobile applications) (collectively the “Site”) as well as our collection of personal information through other channels, whether online or offline. Our Site may contain links to websites operated by Ironwood’s product co-promotion and co-marketing partners or other third parties. Your interaction with any websites operated by such partners are governed by the privacy policies posted on those websites. We do not control, nor are we responsible for, third parties’ privacy practices.
3.0 What Categories of Personal Information May Ironwood Collect?
We may collect (or may have collected in the preceding 12 months), the following personal information about you based on your interactions with us:
- Identifiers, such as your name, address, telephone number, mobile number, email address, driver’s license or state identification number, and other similar contact information and identifiers.
- Financial information, such as your bank account information.
- Demographic information, such as protected classifications under California or federal law, which may include age, date or birth, or gender.
- Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including but not limited to 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, including without limitation:
- data submitted with employment applications including salary history, employment history, and employment recommendations;
- 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, such as education history.
- Geolocation data, such as GPS location data from company-issued mobile devices or vehicles.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Sensitive personal information, such as your Social Security number, driver’s license or state identification number, and your racial or ethnic origin.
- Inferences drawn from the PI in the categories above.
4.0 How Does Ironwood Get Your Personal Information?
We collect personal information directly from you that you submit to us. We will ask you for personal information when you interact with us, using any interactive features or applications, signing up to receive a newsletter, participating in an incentive or savings program, contacting us to ask questions, doing business with us, or seeking or maintaining employment or an internship with us.
5.0 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;
- 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.
Sensitive personal information is only used to manage our employment or other contractual working relationship and fulfill our duties as an employer. We do not use or disclose your sensitive personal information except as stated in this Policy or otherwise permitted by California Privacy Law.
We reserve the right to use de-identified or aggregated data for any purpose and without limitation, and we will not attempt to re-identify the information.
6.0 Who Do We Share Your Personal Information With?
As a reminder please know that Ironwood does not sell your personal information and that we have not sold any personal information in the past 12 months. In addition, we do not share or distribute your personal information with any other company for their marketing purposes. We may share your personal information with the following categories of third parties for the purposes described above:
- 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.
In the preceding 12 months, we have disclosed personal information for our business purposes. With respect to each category of personal information we collect (see Section 3 above), we disclose such personal information to our service providers, including our IT, HR, financial, and commercial (analytics, marketing) vendors. Note, however, that we do not share any employment-related personal information with our commercial vendors.
7.0 Data Security & Retention
Ironwood employs reasonable physical, technical, and administrative safeguards to protect personal information from unauthorized access, disclosure, use, loss, misuse, or unauthorized alteration, or destruction. Please note, however that, notwithstanding these safeguards, it is impossible to guarantee 100% security in all circumstances.
We will retain your personal information for as long as needed to satisfy the purposes for which we collected it, to comply with any applicable legal, accounting, or reporting requirements; to establish, exercise, or defend legal claims; or for our legitimate purposes. Requests to delete your personal information are subject to these obligations and restrictions.
8.0 Authorized Agents
If you would like, you can empower someone else (an “Authorized Agent”) to exercise your rights under this Policy on your behalf. If your Authorized Agent sends us a request to exercise your rights under this Policy, we may: (i) ask that person to provide written proof that you gave that person permission to make the request on your behalf; (ii) seek to verify your identity directly; and/or (iii) ask that you confirm the Authorized Agent’s authority. If we do not receive this information, we may deny their request so that we can protect your personal information.
9.0 Children’s Privacy
The Site is not directed at children under the age of 16, and we do not knowingly collect any personal information of anyone under the age of 16. We also do not knowingly disclose personal information about children under the age of 16 to third parties for monetary or other valuable consideration (i.e., “sell” or “share,” as those terms are defined in California Privacy Law).
If you believe your child is using our website, please contact us using one of the three ways listed in Section 2 of this Policy. We will delete any information we have collected or received from a child under the age of 16 without verification of parental consent.
We may update this Policy to reflect changes in the ways we collect, use, and disclose personal information, or in applicable law. When we update this Policy, we will indicate when it was most recently updated by noting that date in this Policy. Should we make a material change to this Policy, we may provide you with notice prior to the update going into effect, including by posting a conspicuous notice on our Site. Unless otherwise indicated, revisions to this Policy are effective immediately upon posting.
Last Updated Date: June 16, 2023