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This Website Privacy Policy explains how West Pharmaceutical Services, Inc. and its subsidiaries (“West”) use and protect any information that you give to us. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, transfer, process, use and disclose your data and sets out our security practices.

By using this website, you agree and consent to the transfer, processing, use, and disclosure of your information as described in this Privacy Policy.

What we collect

We collect personal data that you provide to us, which is information that identifies you as an individual. We do this only when you have agreed to our request for that information. You may withdraw your consent to the processing of your personal data at any time by contacting us (see the “Contact us” section below).

This personal data may include your name, postal address, telephone number, e-mail address, or other information provided by you so that you may receive information about West, register for West programs, contact West customer service, request a Letter of Authorization for reference to a Drug Master File, respond to West surveys or for reasons related to West’s legitimate business interests of improving and enhancing our products and services.

We may also collect information about your visits to West web sites without you actively submitting such information. For example, unidentifiable information may be collected using various technologies such as cookies. Your internet browser automatically transmits to our web sites some of this unidentifiable information, such as the URL of the web site you just visited and the browser version on which your computer is operating. Passive information collection technologies can make your use of our web sites easier by allowing us to provide better service, customize sites based on preferences, compile statistics, analyze trends, and otherwise administer and improve our web sites. Certain features of our web sites may not work without use of passive information collection technologies. Information collected by these technologies cannot be used to identify you without additional identifiable information.

How we use personal data

West will use personal data that you agree to provide to us to respond to your queries, to provide information or access to online resources you have requested, and to provide you with efficient customer service. West may also use personal data to market products and services that we think may be of interest to you, but only in accordance with local privacy or e-marketing laws, to enforce compliance with this website’s terms of use or to protect our service, website or other users.


Website and mobile application usage information

We also automatically collect information about your computer browser type and operating system, websites you visited before and after visiting our websites, standard server log information, and Internet Protocol (IP) addresses. This information is pseudonymized and is not personal data. We aggregate this information to understand how our visitors use our websites so that we can improve the experience and services that we offer. We may also share this aggregated pseudonymized information with other companies within West and with third parties. This information may include the total number of visits, number of visitors and the domain names of our visitors’ internet service providers.

How we protect your personal data

We use data networks protected by industry standard security systems to ensure the security and confidentiality of Data that we collect online. When handling your personal data, we take reasonable measures to protect that information from loss, misuse, unauthorized access, disclosure, alteration or destruction.

When we may transfer your personal data

We will not sell, share, or otherwise distribute your personal data to third parties except as provided in this Privacy Policy.

West is a global group of companies that has databases in different countries. We may transfer your data to other West affiliates worldwide or to one of the company’s databases outside your country of domicile, potentially to countries whose laws may not require the same level of protection for your personal data compared with that provided in your country. Such West affiliates agree to treat your personal data in accordance with this Privacy Policy.

West has entered into controller to controller Standard Contractual Clauses (SCCs) globally which govern and protect the transfer of data from the EU West entities to West entities outside the EU.

Personal data may also be transferred to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed, such as services delivery, evaluating the usefulness of this website, marketing, data management or technical support. These third parties have contracted with us to only use personal data for the agreed upon purpose and have agreed not to sell your personal data to third parties, nor to disclose it to third parties except as may be required by law, as permitted by us or as stated in this Privacy Policy.

Personal data collected from you may also be transferred to a third party in the event that West or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat personal data in accordance with this Privacy Policy. Also, personal data may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

In order to protect the transfer of personal data from the EEA to a third party located outside the EEA, West would provide for adequate safeguards, such as the Standard Contractual Clauses.

Use of IP addresses

West, or third-party companies acting on our behalf, may collect IP addresses for the purposes of systems administration and to audit the use of our websites. We also may use IP addresses to identify users of our websites when we feel it is necessary to enforce compliance with the websites’ terms of use or to protect our service, websites or other users.

Cookies

Our websites and mobile applications may use technology called "cookies." A cookie is a small text file that is placed on your hard disk by a server. Cookies allow our websites and mobile applications to respond to you as an individual. The website or mobile application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to a website.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or receive a warning before a cookie is stored if you prefer. Please refer to your Internet browser’s instructions or help screen to learn more about these functions and to specify your cookie preferences.

If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites or any other websites that you visit.

Information from outside sources

Where permitted by local law, we may collect legally obtained information from third parties to add to our existing user databases. Some of this information may be personal data. We do this to better target information offerings and promotional campaigns in which we think you would be interested. Such personal data will only be collected and used by us in accordance with the legal basis on which it was originally provided by the subject, or as otherwise permitted by local law.

Data retention, right of access, objection, correction, deletion and portability

We will retain your information only for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. You may contact us in writing to request to update, correct, or remove personal data that you have provided to us at any time using the contact information provided at the end of this Privacy Policy. In the case of electronic direct marketing, we will provide you with a method to opt out of receiving further marketing materials or with a method to opt in if required by law. Requests to delete personal data will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on us.

You also have a right to data portability which gives you the right to receive your personal data in a structured, commonly used and machine readable format and to request us to transmit such personal data to another data controller, where applicable.

Automated decision-making

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved. As a rule, West does not make automated decisions for personal data. If automated decisions are made, affected persons will be given an opportunity to object to them.

Links to other websites

Our websites and mobile applications may from time to time provide links to or embed third party websites. This Privacy Policy does not apply to those websites. If you choose to enter such a linked site, you agree that we are not responsible for the availability of such websites and do not review or endorse and shall not be liable, directly or indirectly, for how these websites treat and use your personal data, or for the content and use of the websites.

Use of our websites and mobile applications by children

West is committed to protecting the privacy of children. We do not knowingly collect personal data from visitors under the age of 13.

Changes

We may occasionally update this Privacy Policy. If the changes are material, we may post a notice regarding the changes on our websites or mobile applications and related licensing agreements. We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the personal data we collect. Subsequent changes in this Privacy Policy will not necessarily apply to data that were collected before the change was made, unless required by law.

Contact us

• For any questions, comments and requests for correction, deletion and portability of your data, please complete this form

• Please address any other questions regarding this Privacy Policy to:

         Susan Morris
         Senior Counsel & Chief Compliance Officer
         Email: susan.morris@westpharma.com


Be sure to include information on how you can be contacted.


Complaints

If you feel that West has violated EU legislation relating to data protection, you have the right to lodge a complaint with a supervisory authority located in the EU.

This Privacy Policy was last updated on May 24, 2018.