Privacy Policy for the United States and Canada

Bavarian Nordic Inc. based in the United States, and Bavarian Nordic Canada, Inc. is based in Ontario, Canada, and both the US and Canadian corporations are wholly owned subsidiaries of Company A/S (“Company”), a Denmark-based company. The privacy policy that is applicable to you will depend on where you are located and how you interact with Company. In general, most visitors to our websites from the United States and Canada will be subject to the following privacy policy.

Please note that there are also additional notices for residents of the following states:

Notice for California and Texas Residents
Consumer Health Data Privacy Policy for residents of Washington and Nevada
Notice for Canada Residents 

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United States and Canada Privacy Policy

Protecting Your Privacy. We urge all users of our websites and other online services that link to or post this Privacy Policy to read the applicable Privacy Policy to learn more about the policies and practices that we have developed to safeguard personal information, and to better understand our relationships with the third parties who may have access to this information.

By using the Services (our websites or programs), you agree to the processing of your information as described in this Privacy Policy. This operates in conjunction with and is subject to our Terms of Use from the site that you visited or our general Terms of Use, which governs our relationship with you. Your use of the Services and any information you provide through the Services is at all times subject to this Privacy Policy and the terms of use applicable to the website you visited. Our Services are not intended to be accessed by individuals under the age of 18.  

Information We Collect. We have access to information regarding you and your visit to the Services that are listed in the sections below. Only some of these categories of information identify you directly, but each category offers some information about your interests and activities that could be used to make inferences about you. If the information permits us to identify you directly or indirectly and is considered personal data in the European Union (EU) according to the provisions of the EU General Data Protection Regulation (GDPR), and if such information is collected or processed in the EU, we will collect or process it in accordance with the requirements of the EU GDPR. Where you are dealing only with Bavarian Nordic Inc., a US organization, that entity will control and be responsible for the collection and processing of your personal data. Your information may be processed in the United States or Canada, and in some cases, transferred to Denmark, Germany, Switzerland or another country (for example, when you report safety information or apply for a role with Company). If your data is transferred to the EU, GDPR rules will apply.

Information That You Voluntarily Provide:

Services Registration. Company has constructed certain Services so that individuals may visit us and review information about the products we offer without registering. If you choose to register to receive information from Company, we will collect “personally identifying information” or “personal data” from you, such as your name, address, telephone number and email address. Your personal data will be used for the purposes of contacting you and providing you with relevant content. We may also use anonymized data that do not allow us to identify you that will still help to provide you with relevant content. Your personal data will not be used for any purposes other than that outlined in this Privacy Policy. We will only share your information with third parties who work directly with us and who are responsible for maintaining and/or processing the data as discussed below or providing our services or our content to you, unless we are required to do so by legal obligations. By registering to use Company’ features and services you explicitly consent to the collection and processing of your personal data for the above purpose. You also consent to the access and processing of your personal data by the third parties as discussed in this Privacy Policy. Your information may also be collected by your internet service provider, browser, search engine or other third-party service provider; the Company is not responsible for this data collection.

By registering you also agree that cookies may be placed on your computer in order to collect information regarding your use of the Services and your preferences as described in the “Cookies” section below.

Other Information You Provide. We and our service providers may collect any other information that you provide when you use the Services, such as when you search for content, sign up to receive communications from Company, or use tools provided on the Services to identify resources that may be of interest to you. In using the Services you may provide us with information on your areas of interest or location. We also collect any information that you provide when you contact us directly, such as with a comment, question, or request. We use this information to provide you with the Services that you have requested and treat the information according to this Privacy Policy.

Information That Is Routinely Collected By Our Services:

• IP Address. We record and retain the Internet Protocol (IP) address of your computer or connected device when you visit the Services.

• Cookies. The Services may use cookies, web beacons and similar technologies including, but not limited to, pixels and tags, and may place such technologies on your personal computer or any other device you may use to access the Services. A cookie is a small file of letters and numbers downloaded onto a device when the user accesses certain websites. Cookies allow a website to recognize a user’s device. Web beacons are small strings of code that the Services may use to deliver small graphic images on a web page or in an email. Web beacons may recognize certain types of information on your computer, such as cookies and the time and date a page is viewed.

• How We May Use Your Information. We may use the information about your use of the services and information on the Services to monitor user traffic patterns; analyze what our users prefer so that we can design better services and activities for you; deliver advertisements that may be of interest to you, including on other sites; and otherwise as described in this Privacy Policy.

• Personally Identifying Information. You do not have to register to use most of the information and services available on the Services. If you choose to join a specific program we offer that requires registration, we will use the personally identifying information or personal data you give us to send you an email or text confirming your registration with the Services. We may also, from time to time, send you emails or texts with special promotions or newsletters with information that we think may be of interest to you, or to otherwise communicate with you or respond to your requests.

• Vendors and Suppliers. We may from time to time have relationships with different vendors and suppliers who help us design and maintain our systems and our computer security, and respond to email and inquiries from users of the Services, or who otherwise provide services to us in connection with our business operations. We will not authorize our vendors and suppliers to access or use the information that has been collected concerning registered users of the Services for any purpose not related to our business.

• Employment Applications and Information. Data submitted related to employment applications and information are subject to the terms and conditions and privacy policy on the portal where you submit that information.

• Law Enforcement. In certain limited circumstances, we may be called upon by the competent authorities in the EU and the U.S. to release your personally identifying information or personal data in response to a court order, subpoena, search warrant, law, or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personally identifying information or personal data that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to other users of the Services. We may also use your personal data to prevent fraud or other unauthorized or illegal activity, to protect and enhance the safety and security of our Services, and to enforce our policies.

• Product Reports. If you communicate with us through the Services regarding your experience with any of our products, we may use the information you provide in submitting reports to the U.S. Food and Drug Administration, the competent authorities in the EU, and as otherwise required of us by law.

• Healthcare Professional Data. We gather and receive healthcare professional data from a variety of sources, including commercial databases, attendance information provided to conferences or trade shows, customer lists from purchasing from our Company or our suppliers, and other information you may choose to provide. We will make reasonable efforts to respect your requests not to be contacted. If you are a California resident, please see below.

• Our Relationship to Third Parties. We may use third parties to provide services and information on the Services and we may provide some co-branded services in partnership with others. We also may use third parties to analyze data collected on the Services. We will not disclose your personally identifying information or personal data to anyone other than our employees, contractors and those third parties with whom we have a business relationship. If we allow a third party contractor to have access to your personally identifying information or personal data, they will only be permitted to access it or use it for purposes that are consistent with and outlined in this Privacy Policy. We pledge that we will not sell or disclose any personally identifying information or personal data you provide on the Services to an unrelated third party without your express permission, except that we may partner with other companies to provide you with content or services on a joint or “co-branded” basis. At a co-branded site you will see both the Company logo and the logo of the co-branded partner displayed on your screen. To access the services available on a co-branded site you may have to complete an online registration form, and this registration information may be shared with our co-branded partners. This Privacy Policy will not apply to co-branded sites. You should read the individual privacy policies of the co-branded sites, as these may differ in some respects from ours. Reading these policies will help you to make an informed decision about whether to provide your information to a given site. Remember, you may always opt-out of sharing your information with a partner site by choosing not to use the service or content provided by the co-branded site.

Other Important Information About Our Relationship With Third Parties:

• Links to Other Sites. The Services also feature links to websites that we believe you might find useful and informative. Please be aware, however, that, other than the websites controlled by Company, we do not endorse or recommend these sites’ content or services, and we are not responsible for the privacy practices of these other sites. We encourage you to be aware of and read the privacy policy of each site you visit. Remember, the statements in this Privacy Policy apply solely to information collected by Company through the Services.

• Advertisers and Sale of Your Data. We do not permit third-party advertisers to display their advertisements on our websites, and we do not sell your data to third parties. 

• Your Privacy Choices. You may elect to receive email updates about information regarding Company, its products, and/or disease states. When you subscribe for email alerts through the Services, you will receive an email to confirm your request. If you decide, at any later time, that you no longer wish to receive these emails you may unsubscribe from that email list by following the “unsubscribe” link at the bottom of your email alert.

• Deletion Policy. The information that you provide to us is stored on servers that are operated and maintained by Company and third parties under contract with Company. Users of the Services should be aware that it is not technologically possible to remove from our servers each and every record of the information you have provided to Company. The need to back-up our systems to protect information from inadvertent loss means that a copy of information about you and personal data may exist in a non-erasable form that will be difficult or impossible for us to locate. Please be aware that we may not comply with an individual’s request to amend or remove certain information that we are not required to delete or are required to keep to comply with our legal obligations, for example, data related to clinical trials or adverse events.

With the exceptions of any of our websites which are subject to EU privacy laws, including the EU GDPR, we do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of personally identifiable information over time and across third-party websites. If we do so in the future, we will describe how we do so in the Privacy Policy.

Our Security Measures. We want your personally identifying information and personal data to remain as secure as reasonably possible.

Data Security. We use security practices to help ensure the integrity and privacy of some of the personally identifying information and personal data you provide to us. As an added security precaution, all personally identifying information and personal data is kept physically behind firewalls that meet or exceed industry standards to prevent intruders from gaining access. Although we will make reasonable efforts to protect personally identifying information and personal data from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could intercept an Internet transmission, or that thieves will find a way to thwart our security systems.

Changes in Our Privacy Policy. We reserve the right to change the terms of this Privacy Policy at any time by posting revisions to this page. If we make any material changes, we will take reasonable steps to notify you (by email or by means of notice on this website) and to obtain any necessary consents required by law. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions about this Privacy Policy please contact us at USPrivacy@bavarian-nordic.com.

Notice for California and Texas Residents

• In addition to the above, Company may collect any information that you submit for the purposes of fulfilling your requests, administering a program, or responding to your inquiries – for example, your email address or phone number, and the information you provide us to assist you. This information may be provided to third parties as necessary to provide you with assistance or to fulfill your request.
• Company may process sensitive data related to applications that you submit to us for employment or employment application purposes, your voluntary participation in clinical trials, adverse events related to our vaccines submitted by you or your healthcare providers or that we become aware of, and inquiries that you submit related to your health or our vaccines. This information may be processed by third parties who help to administer our programs or analyze our data (for example, contract research organizations, clinical trial sites, call center processors) or forwarded to relevant government agencies (for example, the Food and Drug Administration). We are required to keep certain records for certain periods of time and to keep some information indefinitely. From information that you submit to us or your activity related to our websites, we may also collect certain information related to your interests that could include sensitive information related to your geolocation or personal characteristics and demographics to help provide you with more relevant content. We will not sell your sensitive data.
• For California Residents: You have the right to know what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information; the right to delete certain personal information; the right to opt-out of the sale of personal information; the right to correct inaccurate personal information; the right to limit the use and disclosure of sensitive personal information; and the right to non-discrimination when you exercise a privacy right. To exercise those rights, you may email us at USPrivacy@bavarian-nordic.com or leave a voicemail at 1-877-882-7434. Please specify that you are a California resident, and please provide sufficient information to identify you and communicate with you to fulfill your request. Generally, we will retain information long enough to meet any statutory, regulatory or other obligations and to fulfill your request. Most data we collect that we are able to identify as from a California resident is deleted within 5 years unless we are required to retain it for longer.  If you are a healthcare provider, we may also receive information related to your practice or contact information from a variety of sources, including vendors, conferences you attend or other organizations you are a member of. This information may be used to contact you with additional information related to our products, for important safety or regulatory updates, for recalls, for data analysis and optimization of our business processes, or to provide you with more relevant information and content.
• For Texas Residents: Consumers who are residents of Texas are entitled to exercise certain consumer rights by submitting a request specifying the right you wish to exercise. These rights do not apply to information that we are required to collect for regulatory purposes, to information related to clinical trials, and to certain other health records. You can learn more about your rights here. To exercise these rights you may email us at USPrivacy@bavarian-nordic.com or leave a voicemail at 1-877-882-7434. Please specify that you are a Texas resident, and please provide sufficient information to authenticate your request. To appeal a decision related to your data request, please explain the rationale for your appeal, provide sufficient information to authenticate your request, and email us at USPrivacy@bavarian-nordic.com.  

Notice for Residents of Canada

• Bavarian Nordic Canada Inc. complies with the principles of the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and relevant provincial laws. Residents of Canada have the right to request additional information regarding the existence, use and disclosure of their personal information and to be given access to their personal information. To exercise these rights, you may email us at USPrivacy@bavarian-nordic.com. Please specify that you are a Canada resident, and your province, and please provide sufficient information to authenticate and fulfill your request. Residents of Alberta, Quebec, and British Columbia have the right to request certain corrections of their data and/or to withdraw consent.
• The individual responsible for compliance with Canadian privacy law is Virginia Fitt, Head of Legal and Compliance, North America. She may be contacted at USPrivacy@bavarian-nordic.com.  

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Last Updated: April 2024