Privacy Policy

Whose personal information we collect

We collect personal information about the following types of individuals: clinical trial participants, patients, patient family members, caregivers or advocates, physicians and other health care professionals, clinical trial investigators, researchers, pharmacists, and other individuals who interact directly with Mirum or its service providers or business partners, including users of websites and mobile applications.

How we collect personal information

We collect personal information:

• Directly from individuals
• Through our websites and mobile apps
• From healthcare professionals
• From contract research organizations and clinical trial investigators
• From government agencies or public records
• From third party service providers, data brokers, or business partners
• From industry and patient groups and associations

Types of personal information we collect

The types of personal information we collect and share depend on the nature of the relationship you have with Mirum and the requirements of applicable laws. We may collect:

• Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, and medications an individual may take, including the dosage, timing, and frequency) we collect in connection with managing clinical trials, conducting research, providing patient support programs, managing compassionate use and expanded access programs, and tracking adverse event reports. Any information that is “protected health information” for purposes of the U.S. Health Insurance Portability and Accountability Act (“HIPAA”) is subject to the HIPAA covered entity’s Notice of Privacy Practices.
• Personal and business contact information and preferences (such as name, job title and employer name, email address, mailing address, phone number, and emergency contact information)
• Biographical and demographic information (such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians)
• Professional credentials, educational and professional history, and institutional affiliations
• Payment-related information we need to pay for professional services, such as consulting, that individuals may provide to us (such as tax identification number and financial account information)
• If you are a healthcare professional, we collect information about the programs and activities in which you have participated, your prescribing of our products, and the agreements you have executed with us
• Your photograph, social media handle, or digital or electronic signature
• Publicly available information (such as comments describing support for and experience with Mirum products)
• Other information you provide to us (such as in emails, on phone calls, in market research surveys, or in other correspondence with Mirum or its service providers or business partners).

We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide to us through our Services.

Information automatically collected

We may automatically log information about you and your computer or mobile device when you access or interact with our Sites. For example, we may log your device or computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Sites, pages you viewed, how long you spent on a page, access times, and information about your use of and actions on our Sites. We collect this information about you using cookies, server logs, web beacons, pixels, and similar technologies about your device, and your use of our Site and services. Please refer to the Cookies and Similar Technologies section for more details.

This California Consumer Privacy Act disclosure (“Disclosure”) is effective as of January 1, 2021. The general Privacy Policy describes the personal information that we collect, the sources from which we collect it, the purposes for which we use it, the limited circumstances under which we share personal information, and with whom we share it. These additional disclosures are required by the California Consumer Privacy Act:

Categories of personal information collected.

The personal information that we collect, or has collected from consumers in the twelve months prior to the effective date of this Disclosure, fall into the following categories established by the California Consumer Privacy Act:

• identifiers such as your name, alias, address, phone numbers, or IP address;
• personal information;
• age, gender, or other protected classifications;
• internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details;
• geolocation data, such as the location of your device or computer;
• professional information, for example data you may provide about your business if you are a prospective customer or healthcare professional; and
  behavioral data, such as information about your purchase preferences, if such services are active.

Please review this full Privacy Policy to see all of the data we collect, if not listed above.

Categories of personal information disclosed for a business purpose. The personal information that we disclose to the third parties identified in the “HOW DO WE USE YOUR PERSONAL INFORMATION?” section of this policy in the twelve months prior to the effective date of this Disclosure would or do fall into the following categories established by the California Consumer Privacy Act:

• identifiers such as your name, address, phone numbers, or IP address, for example if we use a third party carrier to deliver services to you;
• personal information, for example if we use a third party information processor;
• your age, gender, or other protected classifications;
• commercial information, such as the details of a product or service you requested if a third party service provider is assisting to provide that product or service to you;
• internet or other electronic network activity information, such as if we use a service provider to help us gather crash reports for analyzing the health of our devices and services;
• geolocation data, such as limiting information to locations where our products are approved;
• audio or visual information, for example if a service provider reviews recordings of customer service phone calls for quality assurance purposes;
• and professional information, for example if we provide your account details to a service provider for follow up on professional information requests.

Right to Request Access to or Deletion of Personal Information: You may have the right under the California Consumer Privacy Act to request information about the collection of your personal information by us, or access to or deletion of your personal information. If you wish to do any of these things, please contact privacy@mirumpharma.com. Depending on your data choices, certain services may be limited or unavailable.

No sale of personal information. In the twelve months prior to the effective date of this Disclosure, Mirum has not sold any personal information of consumers, as those terms are defined under the California Consumer Privacy Act.

No Discrimination. Mirum will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.

To Operate Our Websites and Mobile Apps

If you use our websites or mobile apps, we use your personal information to:

• Operate, maintain, administer, and improve the websites and mobile apps
• Better understand your needs and interests and personalize your experience with the websites and mobile apps
• Provide support and maintenance for our websites and mobile apps
• Respond to your service-related requests, questions, and feedback

To Perform and Administer Clinical Trials, Research, and Product-Improvement Activities

We may use your personal information when necessary to facilitate our clinical trials, research, studies, and related activities that support product improvement, including to:

• Staff and manage clinical trials, including by recruiting investigators and participants
• Track and respond to safety and product quality concerns (including product recalls)
• Support public health initiatives, symposia, conferences, and scientific, educational, and volunteer events
• Define and manage appropriate patient engagement activities and patient support programs (including to provide co-pay and other financial assistance where available)
• Identify and engage thought leaders and external experts
• Award scholarships and grants
• Attribute authorship to academic and promotional materials.

To Provide Products and Services

We use your personal information as necessary to provide Mirum products and services, including to:

• Manage access to our products, including where access is limited by law to licensed physicians
• Pay for services that physicians, researchers, and other individuals may provide to us.

To Communicate With You

If you request information from us or participate in our surveys, promotions, or events, we may send you Mirum-related product or disease-related communications as permitted by law. You will have the ability to opt out of such communications.

To Comply With Law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

To Comply With Regulatory Monitoring and Reporting Obligations

We use your personal information as we believe necessary or appropriate to comply with regulatory monitoring and reporting obligations, such as those related to adverse events, product complaints, patient safety, and financial disclosures.

With Your Consent

We will request your consent to use your personal data where required by law, such as where we use certain cookies or similar technologies or would like to send you certain product-related messages. If we request your consent to use your personal data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us.

To Create Anonymous Data for Analytics

We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.

For Compliance, Fraud Prevention, and Safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our websites, mobile apps, products, and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

If you use our websites or mobile apps, we use your personal information to:

• Operate, maintain, administer, and improve the websites and mobile apps
• Better understand your needs and interests and personalize your experience with the websites and mobile apps
• Provide support and maintenance for our websites and mobile apps
• Respond to your service-related requests, questions, and feedback.

The security of your personal information is important to us. We take a number of organizational, technical, and physical measures designed to protect the personal information we collect, both during transmission and once we receive it.

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via email (if we have your email address) or another manner that we believe reasonably likely to reach you (which may include posting a new privacy policy on our websites or a specific announcement on this page).

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes (or as otherwise indicated at the time of posting). In all cases, your continued use of our websites, mobile apps, products, and services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Personal Information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller and Data Protection Representative

Mirum is the Data Controller of your personal information. For its clinical programs, Mirum ensures the processing of personal data by ClinEdge, LLC is compliant with the European Data Protection Regulations and National Laws. As Mirum is located in the United-States [989 E Hillsdale Blvd., Suite 300, Foster City, CA 94404], Mirum has appointed a Data Protection Representative, MyData-Trust. MyData-Trust can be contacted at:

• mirum.dpr@mydata-trust.info
• MyData-TRUST SA, Boulevard Initialis 7/3, 7000 Mons, Belgium

Legal Bases for Processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described below. If you have questions about the legal basis of how we process your personal information, contact us at privacy@mirumpharma.com.

To provide our products and services: Where we have a contract governing this processing purpose, the processing is necessary is perform that contract, or necessary to take steps that you have requested prior to entering into the contract. In other cases, these processing activities are necessary to protect your, or another person’s, vital interests.

To perform and administer clinical trials, research, and product-improvement activities: Where we have a contract governing this processing purpose, the processing is necessary is perform that contract, or necessary to take steps that you have requested prior to entering into the contract.

Where we process sensitive personal data in connection with this processing purpose, the processing is necessary for scientific or historical research purposes or statistical purposes.

In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To operate our websites and mobile apps; communicate with you; create anonymous data for analytics; or for compliance, fraud prevention, and safety: These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with law and regulatory monitoring and reporting obligations: Processing is necessary to comply with our legal obligations.

With your consent: Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated when we requested the consent or by contacting us.

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and when the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fullfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.