ELANCO GLOBAL PRIVACY CENTER

ELANCO GLOBAL PRIVACY NOTICE


Your privacy is important to us. Elanco Animal Health Incorporated and its affiliates (collectively, "Elanco,” “we,” “us,” “our”) has established a comprehensive privacy program designed to help us respect and protect your privacy rights. This notice (the “Privacy Notice”) provides information about the personal information Elanco collects (“Personal Information”) and explains how we collect, process, disclose, and safeguard Personal Information, as well as your rights and choices with respect to your Personal Information.

Elanco operates in many different countries and regions. Some of these countries or regions have laws related to the processing of Personal Information. Elanco takes these obligations seriously and is committed to protecting your privacy.

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A. Scope

This Privacy Notice describes the privacy practices of Elanco and applies to all Elanco operations including:

Websites or digital services operated by us;

Mobile and other software applications;

Social media pages that we control;

Email messages and other communications that we send to you; and

Other ways in which we communicate with you or collect Personal Information from or about you, via our online and offline programs and services.

Collectively, we refer to these operations in this Privacy Notice as the “Services.”

Please note that this Privacy Notice does not apply to applicants, employees, independent contractors, or other individuals with whom we interact in an employment-related capacity (our “Workforce”). Members of our Workforce may access the Elanco Workforce Privacy Notice by clicking here.

Some portions of this Privacy Notice apply only to Customers and/or Consumers in particular regions, countries, or U.S. states. In those instances, we have indicated that such language applies only to certain Customers and/or Consumers.

 

 

B. Definitions

“Consumer” means any natural person, other than Customers and Workforce members.

“Customer” means any natural person with whom Elanco interacts in a business-related capacity.

“Individual” includes both Consumers and Customers.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes “personal data” (or equivalent terms) as that term is defined by applicable privacy laws. Personal Information also includes “Sensitive Personal Information,” as defined below, except where otherwise noted.

“Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” (or equivalent terms) as that term is defined by applicable privacy laws.

“Supplier” means a service provider, contractor, or processor as those terms are defined by applicable privacy laws.

“Third Party” means any entity that is not a Supplier.

“U.S. Privacy Laws” means the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020, and their implementing regulations (collectively, the “CCPA”), the Colorado Privacy Act of 2021 and its implementing regulations (collectively, the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), the Connecticut Data Privacy Act of 2022 (“CDPA”), the Iowa Consumer Data Protection Act of 2023 (the “ICDPA”), the Indiana Consumer Data Protection of 2023 (the “INCDPA”), the Montana Consumer Data Privacy Act of 2023 (the “MCDPA”), and the Tennessee Information Protection Act (the “TIPA”), collectively.

Other terms used herein that are defined terms under applicable privacy laws shall have the meanings afforded to them by applicable privacy laws, whether or not capitalized, unless the context indicates otherwise. As there are some variations between such definitions across global privacy laws, the definitions applicable to you are those provided in the statute for the region, country, or U.S. state in which you are a Customer or Consumer. For example, if you are a California Consumer, terms used in this Privacy Notice that are defined terms in the CCPA shall have the meanings afforded to them in the CCPA as this Privacy Notice applies to you.

 

 

C. Overview of Personal Information Processing & California Notice at Collection

This section of our Privacy Notice lists the categories of Personal Information Elanco and our Suppliers collect and explains how we and our Suppliers process that Personal Information. This section also provides our notice at collection for California Customers and Consumers.

 

 

1. Information We Collect and How We Use It

We collect the following categories of Personal Information from Customers and Consumers, and we have collected the following categories of Personal Information from Customers and Consumers in the past twelve months:


1. Identifiers, such as name, alias, IP address, online identifiers, browser and mobile application identifiers, account name, physical characteristics or description;


2. Contact and financial information, including phone number, address, email address, medical information;


3. Characteristics of protected classifications under state or federal law, such as age and gender;


4. Commercial information, such as transaction information and purchase history;


5. Biometric information


6. Internet or other electronic network activity information, such as browsing history, interactions with our websites or advertisements, and information collected via cookies, pixels, and similar digital tracking technologies;


7. Geolocation data, such as device location;


8. Audio, electronic, visual and similar information, such as call and video recordings;


9. Professional or employment-related information, such as work history and prior employer;


10. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics; and


11. Sensitive personal information, including:

      a.    Personal Information that reveals:
                   i.  Social security, driver’s license, state identification card, or passport number; 

                        

                       or


                   ii.  Precise geolocation;

      b.    Biometric data processed for the purpose of uniquely identifying a Customer or Consumer.


We have disclosed the categories of Personal Information listed in this Section C(1) to Third Parties for a business purpose in the past twelve months.

 

 

4. Sale, Sharing, & Processing for Purposes of Targeted Advertising

Disclosure for California Customers and Consumers: We sell and share each of the categories of Personal Information listed in Section C(1) that we collect about Customers and Consumers, and we have sold and shared each of the categories of Personal Information listed in Section C(1) in the past twelve months. We sell and share each category of Personal Information listed in Section C(1) with the categories of Third Parties listed in Section D(1), for the purposes listed in Sections C(2) and (3). We do not have actual knowledge that we sell or share Personal Information of California Customers or Consumers under 16 years of age. For purposes of the CCPA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. California Customers and Consumers have the right to opt out of the sale and sharing of their Personal Information, and can do so by clicking here, sending an email to privacy@elancoah.com, calling us toll free at 1-888-545-5973.


Disclosure for Colorado, Virginia, Utah, Connecticut, Iowa, Indiana, Montana, and Tennessee Consumers: We sell the categories of Personal Information listed in Section C(1) to Third Parties and process the categories of Personal Information listed in Section C(1) for purposes of targeted advertising, as the terms “sell,” “process,” and “targeted advertising” are defined under the U.S. Privacy Law applicable in each state, and to the extent applicable to each state. We sell each category of Personal Information listed in Section C(1) with the categories of Third Parties listed in Section D(1), for the purposes listed in Sections C(2) and (3). Consumers of these states may exercise the opt-out rights applicable to them by clicking here, sending an email to privacy@elancoah.com, or calling us toll free at 1-888-545-5973. These rights to opt-out do not apply to Customers who are residents of these states.

 

 

5. Retention of Personal Information

We will retain each category of Personal Information listed in Section C(1) for the time needed to fulfil our legitimate and lawful business purposes in accordance with our records retention policy and applicable laws and regulations.

The criteria used to determine our retention periods include:


         ∙ The duration of our relationship with you and the time needed to provide the Services to you;


         ∙ Whether there is a legal obligation to which we are subject; and


         ∙ Whether retention is advisable for other legal and regulatory purposes.

 

 

D. Additional Processing Information


1. How We Disclose Your Personal Information

For each of the categories of Personal Information listed in Section C(1), we disclose and have disclosed such Personal Information to our affiliates and Suppliers, and to Third Parties in connection with the Services in the past twelve months:


∙ Elanco Affiliates: We disclose Personal Information to Elanco affiliates for the purposes described in this Privacy Notice, such as providing Services, communicating with you, facilitating programs, and otherwise accomplishing our business purposes. 


∙ Suppliers: We disclose Personal Information to our Suppliers to provide services such as sending email messages, managing data, hosting our databases, providing data processing services, providing customer service, conducting marketing activities, and similar purposes. Our Suppliers are restricted from using this data other than to provide services to us.


∙ Third Party Partners: We disclose Personal Information to other companies, including other animal health companies, for co-marketing, co-distribution, pharmacovigilance, and similar purposes. We also disclose Personal Information to Third Parties for advertising and analytics purposes, including via cookies and similar technologies.


∙ Other Third Parties: We may disclose Personal Information to respond to subpoenas or other lawful information requests from governmental authorities, or to comply with applicable law, including to report adverse events, respond to law enforcement requests, or manage security, emergencies, and incident response. We may also provide your Personal Information to a Third Party in connection with any sale, assignment, or other asset transfer, in which case we will seek assurances that the Third Party will treat the Personal Information in accordance with this Privacy Notice.

 

 

2. Sources of Personal Information

We collect Personal Information from the following sources:


∙ Online Services. We collect Personal Information when you interact with our Services, including when you browse our websites; purchase goods and services from us via the Services; communicate with us; post to social media pages; sign up for a newsletter; participate in a survey, contest, or promotional offer; or otherwise communicate with us.


∙ Visits and Offline Interactions. We collect Personal Information when we visit your place of business. We also collect Personal Information when you attend promotional events that we host, sponsor, or in which we participate.


∙ Customer Service Centers. We collect Personal Information when you communicate with us, including by contacting our customer service department. These communications may be recorded for purposes of quality assurance and training.


∙ Rebate, Reminder, and Loyalty Programs. We collect Personal Information when you participate in a rebate, reminder, or loyalty program.  


∙ Other Sources. We collect Personal Information from other sources, such as public databases; our Suppliers; and Third Parties, including joint marketing partners.

 

 

3. Cookies and Similar Technologies

As provided in Sections C(1) and (2), Elanco and our Suppliers collect Personal Information via cookies and similar technologies for purposes of analytics, auditing, research, and reporting. A cookie is a small data file that is stored directly on the computer or mobile device that you are using. We use cookies and similar technologies to collect information such as browser type, pages visited, referring URL, language preferences, and other aggregated traffic data. We and our Suppliers use:


∙ Strictly Necessary Cookies – To allow you to use and browse our Services.


∙ Functional Cookies – To obtain data for security purposes, and to display content more effectively, collect statistical data, and recognize your computer to assist your use of our Services.


∙ Advertising and Analytics Cookies – To analyze Individuals’ use of our Services, personalize your experience on our Services, and provide you with information and offers that are most likely to appeal to you.


Where legally required, we obtain consent via our cookie banner before collecting Personal Information via cookies or similar technologies (other than those that are strictly necessary).


Further, all Customers and Consumers may change their preferences with respect to the use of cookies and similar technologies on our Services, other than those that are strictly necessary for the operation of the Services, by clicking here.


Depending on your Internet browser, you may also be able to change your settings to block and/or erase cookies from your device. You can check your browser instructions to learn more about these functions. Please note that if you block or reject cookies and similar technologies on our Services, functionality of the Services may be limited, and you may not be able to take advantage of some of the Services’ features.

 

 

4. Third Parties & Digital Advertising

We also allow Third Parties, including Google Analytics, to collect Personal Information via our Services to provide advertising services that are targeted based on your online activities across websites, mobile apps, and devices over time. These Third Parties may collect information about your activities on our Services on your current device and combine it with information about your activities on other websites, mobile apps, and devices. They may collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs, cross-device linking, and similar technologies. For example, these Third Parties may use the fact that you visited our website to target advertising to you on other websites and mobile apps on your current device or on other devices you use.


Residents of certain U.S. states have the right to opt out of the sale, sharing, and/or processing of their Personal Information for purposes of targeted advertising. To exercise such rights, if applicable to you, please click here, send an email to privacy@elancoah.com, or call us toll free at 1-888-545-5973.


You may also be able to change your browser or device settings to limit disclosure of your Personal Information to Third Parties. Please note that we make no representations regarding the functionality or effectiveness of these tools.

 

 

5. Do Not Track & Opt-Out Preference Signals

We recognize opt-out preference signals that we are required to recognize for compliance with applicable law. Where required by applicable privacy laws, we treat such opt-out preference signals as a valid request to opt-out of sale and, as applicable, sharing for the browser or device through which the signal is sent and any Customer or Consumer profile we have associated with that browser or device, including pseudonymous profiles. If we know the identity of the Customer or Consumer from the opt-out preference signal, we will also treat such opt-out preference signal as a valid request to opt out of sale and sharing for such Customer or Consumer. California Customers and Consumers may use opt-out preference signals by downloading or otherwise activating them for use on supported browsers and setting them to send opt-out preference signals to websites they visit.

 

 

6. Children’s Information

Our website is not intended for or designed to attract children under the age of 13. To comply with the Children’s Online Privacy Protection Act of 1998, we only collect personal information about a minor if we have obtained parental consent. If you are the parent or guardian of a minor and believe that we have collected Personal Information about your child in error, please contact us immediately at privacy@elancoah.com so we can make reasonable efforts to delete all Personal Information related to your child.

 

 

7. How We Secure Your Information

We provide reasonable physical, electronic, and procedural safeguards to protect Personal Information collected via our Services. For example, except as otherwise indicated in this Privacy Notice, we limit access to Personal Information to our Workforce members and Suppliers who need access to the Personal Information to perform the activities described in this Privacy Notice. Although we strive to provide reasonable security for Personal Information we process, no security system can prevent all potential security breaches. Accordingly, we cannot fully guarantee the security of the Personal Information we collect about you.

 

 

8. International Transfers of Personal Information

Personal Information we collect from and about you may be transferred outside of your country of residence, including to the U.S. and other countries that may not provide the same level of data protection as your country of residence. Nonetheless, Elanco will process your Personal Information in accordance with this Privacy Notice and applicable privacy laws. Further, when we receive or transfer Personal Information from or to our affiliates, Suppliers, and Third Parties, we implement appropriate safeguards to facilitate such transfers where required by applicable law.

To obtain additional information regarding and/or a copy of the safeguards Elanco has implemented to facilitate cross-border transfers of Personal Information, please contact us at privacy@elancoah.com.

 

 

9. Your Rights & Choices

European Economic Area & the United Kingdom: Customers and Consumers who reside in the European Economic Area or the United Kingdom have rights to access, correct, delete, restrict the processing of, and object to the processing of their Personal Information. They also have rights to obtain their Personal Information in a structured, commonly-used, and machine-readable format for transmission to another data controller, to not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, and to lodge a complaint with a supervisory authority. Further, where we rely on consent as our legal basis for processing, Customers and Consumers who reside in the European Economic Area or the United Kingdom may withdraw their consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.


California: California Customers and Consumers have the following rights regarding our collection and use of their Personal Information, subject to certain exceptions.


∙ Right to Receive Information on Privacy Practices: You have the right to receive the following information at or before the point of collection: (1) the categories of Personal Information to be collected; (2) the purposes for which the categories of Personal Information are collected or used; (3) whether or not that Personal Information is sold or shared; (4) if the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and (5) the length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period. We have provided such information in this Privacy Notice, and you may request further information about our privacy practices by contacting us as at the contact information provided below.


∙ Right to Deletion: You may request that we delete any Personal Information about you we that we collected from you, subject to certain exceptions.


∙ Right to Correction: You may request that we correct any inaccurate Personal Information we maintain about you.


∙ Right to Know: You may request that we provide you with the following information about how we have handled your Personal Information: (1) the categories of Personal Information we collected about you; (2) the categories of sources from which we collected such Personal Information; (3) the business or commercial purpose for collecting, selling, or sharing Personal Information about you; (4) the categories of Third Parties to whom we disclosed such Personal Information; and (5) the specific pieces of Personal Information we have collected about you.


∙ Right to Opt-Out of the Sale and Sharing of Personal Information: You have the right, at any time, to direct us not to sell or share your Personal Information. To exercise that right, please contact us by clicking here, sending an email to privacy@elancoah.com, or calling us toll free at 1-888-545-5973.


∙ Right to Receive Information About Onward Disclosures: You may request that we disclose to you: (1) the categories of Personal Information that we have collected about you; (2) the categories of Personal Information that we have sold or shared about you and the categories of Third Parties to whom the Personal Information was sold or shared; and (3) the categories of Personal Information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.


∙ Right to Non-Discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.


∙ Residents of Colorado: Colorado Consumers have rights to access, correct, and delete their Personal Information, obtain their Personal Information in a portable format, and opt-out of the processing of their Personal Information for targeted advertising, sale, and profiling in furtherance of decisions that produce legal or similarly significant effects concerning a Consumer.


Residents of other countries and regions may have similar rights, depending on their country of residence. For example, residents of some other U.S. states have rights to access, delete, and correct their Personal Information, among others.

 

 

10. Exercising Your Rights

To exercise your data subject rights, you can submit your request here, send an email to privacy@elancoah.com, or call us toll free at 1-888-545-5973. Authorized agents may also submit requests via these methods, where permitted by applicable privacy laws.


Further, to opt out of receiving marketing-related emails, you can use the unsubscribe link at the bottom of any of our email communications, or submit a request via the above methods.


We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

 

 

11. Verification of Data Subject Requests & Appeals

As permitted or required by applicable privacy laws, we may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, when a California Customer or Consumer, or a Colorado Consumer, authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the Customer or Consumer to submit the request, or we may require the Customer or Consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable privacy laws. We will respond to your request consistent with applicable privacy laws.


To appeal our decision on your data subject requests, you may contact our us at privacy@elancoah.com. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

 

 

13. Other Disclosures for California Customers and Consumers

∙ California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by writing to privacy@elancoah.com. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.


∙ Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. To make such a request, please send an email to privacy@elancoah.com with the subject “Shine the Light Request.”


∙ Financial Incentives for California Customers & Consumers. Under California law, we do not provide financial incentives to California Customers or Consumers who allow us to collect, retain, sell, or share their Personal Information. We will describe such programs to you if and when we offer them to you

 

 

14. Disclosure for Nevada Consumers

We sell “Covered Information” as defined under Nevada law, but we generally do not disclose or share “Personal Information” as defined under Nevada law for commercial purposes. Under Nevada law, you have the right to direct us to not sell your Covered Information to third parties, as defined under Nevada law. To exercise this right, if applicable, you or your authorized representative may contact our Privacy Office at privacy@elancoah.com or call us toll free at 1-888-545-5973.

 

 

15. Changes to Our Privacy Practices

We may update this Privacy Notice from time to time. When we do so, we will make the updated notice available on this page. Elanco encourages you to review this page regularly for any changes.

 

 

16. How to Contact Us

To contact us with questions or more information, you can email us at privacy@elancoah.com or call us toll-free at 1-888-545-5973.

To contact our Data Protection Officer responsible for your country or region, please email us at privacy@elancoah.com. In your email, please indicate your country of residence.

Last Updated: 27 June 2023


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