Mirum may provide additional privacy notices to individuals at the time we collect their data. For example, we provide a specific privacy notice to clinical trial participants that describe our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide at that time.
Personal Information We Collect
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
- From social media or other public forums (including adverse event information or product quality complaints).
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
- 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 health care 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 our Sites. For example, we may log your 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. Please refer to the Cookies and Similar Technologies section for more details.
Cookies and Similar Technologies
What are Cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Types Cookies We Use
Essential Cookies: These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies: These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.
Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site.
Targeted and Advertising Cookies: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
Do Not Track Signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
How We Use Your Personal Information
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.
How We Share your Personal Information
We may employ third party companies and individuals to perform services on our behalf, including:
- Contract research organizations that conduct clinical trials
- Data storage and analytics
- Customer service (including our medical information line) and patient support providers (including for product quality and adverse event reporting, patient co-pay assistance, medicine intake adherence programs, etc.)
- Product recall administration
- Technology services and support (including email and web hosting providers, marketing and advertising technology providers, email and text communications providers, mobile app developers)
- Event planning and travel organizations that help facilitate Mirum programs
- Payment, shipping and fulfillment service providers
Business Partners and Other Professionals and Organizations
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety
We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our websites, mobile apps, products and services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Additional Program Terms
In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your data, such as if you participate in a special program, activity, event, or clinical trial. These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about how we will use your information. We will honor these additional terms with respect to your information and thus, strongly recommend you review the additional terms prior to participating in any programs.
Access, Review, Update Your Information
If you become aware that the personal information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, or if you would like to access or review your information, you may contact us at email@example.com.
If you are located in the European Union, please refer to the section “Additional Information for European Union Users”.
You may opt out of product and disease-related communications by clicking the “Unsubscribe” link at the bottom of each such communication, or by sending an email with the subject line “Unsubscribe” to firstname.lastname@example.org. You may continue to receive service-related and other non-product/disease related emails.
Choosing Not to Share Your Personal Information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide you with our products or services, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our products or services and may need to terminate our relationship with you. We will tell you what information you must provide to us by designating it as required when we request the information or through other appropriate means.
The security of your personal information 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.
Mirum complies with the requirements of the U.S. Children’s Online Privacy Protection Act (COPPA) and does not knowingly collect personal information from children under age 13 through our websites or mobile applications. If we learn that we have collected personal information directly from a child under the age of 13 through our websites or mobile applications, we will delete that information.
International Data Transfers
Mirum is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Individuals in the European Union should read the important information provided in the Cross-Border Data Transfer section about transfer of personal information outside of the European Economic Area provided in the Cross-Border Data Transfer sub-section of the section “Additional Information for European Union Users”.
Other Sites and Services
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by Mirum. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Mirum Pharmaceuticals, Inc.
Attn: Chief Compliance Officer
950 Tower Lane, Suite 1050
Foster City, CA 94404
You may also contact us via email at:
Additional Information for European Union Users
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, LCC is compliant with the European Data Protection Regulations and National Laws. As Mirum is located in the United-States [950 Tower Lane, Suite 1050, Foster City, CA 94404], Mirum has appointed a Data Protection Representative, MyData-Trust. MyData-Trust can be contacted at email@example.com.
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 firstname.lastname@example.org.
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 will only retain your personal information for as long as necessary to fulfil 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.
European data protection laws provide certain rights regarding the collection and processing of personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct product or disease-related communications. You may continue to receive service-related and other non-product/disease communications.
- Provide you with information about our processing of your personal information and give you access to your personal information.
- Update or correct inaccuracies in your personal information.
- Delete your personal information.
- Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict the processing of your personal information.
- Object to our reliance on our legitimate interests as the basis of our processing of your personal information.
You can submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on safeguards that allow us to conduct the transfer in accordance with the EEA’s data protection laws, such as the specific contracts approved by the European Commission as providing adequate protection of personal information. For details, see the European Commission’s website for model contracts for the transfer of personal information to third countries.
For further information on the specific transfer mechanism used by us or to receive a copy, please contact Mirum’s EU Data Protection Officer at firstname.lastname@example.org.