Last Updated: May 30, 2019
Our privacy policies, statements, and notices offer details about how personal data is processed by Alnylam Pharmaceuticals and its worldwide affiliates, including how information might be disclosed as well as the rights of individuals.
This website is owned and operated by Alnylam Pharmaceuticals, Inc. (“Alnylam”, “we”, “our” or “us”), a company established under the laws of Delaware with registered offices at 675 W Kendall Street, Cambridge, MA 02142 USA, Tel: 617.551.8200, Fax: 617.551.8101, e-mail: email@example.com.
To learn more about Alnylam and its worldwide presence and how to contact Alnylam’s affiliates directly please visit our corporate website at www.alnylam.com/contact-us/.
For information on the collection, use and processing of personal data of Healthcare Professionals by Alnylam read the specific Privacy Notice for Healthcare Professionals (General Use)
For more information on the collection, use and processing of your personal data for electronic communications purposes, read the specific Data Privacy Notification and Consent Form for electronic communications
For more information on the collection, use and processing of your personal data for electronic communications purposes, read the specific Direct Marketing / Email Communications Notice
For more information on the collection, use and processing of your personal data collected at congresses, read the specific Data Privacy Notice for Use of Personal Data Obtained at Congresses, Symposia and other Events
For more information on the collection, use and processing of your personal data for the purpose of recruitment, read the specific Alnylam Pharmaceuticals Recruitment Privacy Notice
Personal Data Collection and Use
Alnylam respects the privacy of visitors to our website, and we recognize your need for appropriate protection and management of the personal data you share with us. You can visit our website without telling us anything about yourself. If you contact us and choose to provide your personal data, such as your name, address, telephone number or e-mail address, we will collect and use this personal data for the purposes for which you submitted it to us, namely to respond to your inquiry, to provide you with information that you have requested (such information may either relate to our products or services or consist of up-to-date disease awareness information) in the form of sending of newsletters or otherwise, to bill you for products and services you have requested, to market products and services which we think are of interest to you, or to communicate with you for other purposes which are evident from the circumstances or about which we inform you when we collect personal data from you. Such other purposes may include, from time to time, monitoring our regulatory compliance, compiling profiles and personal information about you in order to identify suitable education/awareness programs or suitable opportunities to collaborate with you.
Non-disclosure of Personal Data
Alnylam has not sold personal data in the preceding 12 months.
Your Privacy Rights
Whenever we process personal data concerning you, we take reasonable steps to ensure that your personal data is kept accurate and up-to date for the purposes for which it was collected.
Per applicable law you have the right to access your personal data. Your right of access includes the right to request that Alnylam disclose to you the following: (1) the categories of personal data Alnylam has collected about you; (2) the categories of sources from which the personal data is collected; (3) the business or commercial purpose for collecting personal data; (4) the categories of personal third parties with whom Alnylam shares personal data; and (5) the specific pieces of personal data Alnylam has collected about you.
You also have the right to request that your personal data be deleted or transferred, to the extent that such deletion or portability is technically possible or permitted by law.
Alnylam will not discriminate against you for exercising your privacy rights.
If you wish to contact us to receive further information regarding our use of your personal data, or if you wish to access your personal data, please complete this Data Subject Request form, email us at firstname.lastname@example.org, or call us at 844.543.8355 or as specified in the “For Additional Information” section below.
We will require evidence of your identity or to be provided with additional information before we are able to act on your request when the information, we have is insufficient to accommodate your request. We will attempt to provide any requested information or make requested changes to the extent allowable by applicable privacy laws. In any event, we will respond to you as soon as reasonably possible to advise you of the outcome of your request.
Where cross-border data transfers occur, we ensure that an adequate level of data protection exists in the recipient country, by executing with third parties appropriate contractual arrangements for cross-border data transfers to third countries for controllers or processors as applicable.
An updated list of Alnylam’s data processors can be made available upon request by email at email@example.com.
Alnylam uses commercially reasonable administrative, technical, personnel-related, and physical security measures designed to safeguard the personal data in our possession against loss, theft and unauthorized use, disclosure, or modification.
Alnylam has taken reasonable steps to ensure that appropriate technical and organizational security measures are implemented not only by Alnylam but also by data processors acting for and, on its behalf, to ensure the security of the processing of your personal data overall.
Links to Third Party Websites
Your personal data will be retained by Alnylam for the intended purposes in accordance with applicable data protection laws and company policies. Once your personal data is no longer needed, it will be promptly deleted or anonymized in accordance with Alnylam’s policies.
Our Children’s Policy
We are committed to protecting the privacy of children. You should be aware that this website content and services are not intended for, or designed to attract, children under the age of 18. No personal data should be submitted to Alnylam through the website by visitors who are less than 18 years old. If it comes to our attention that an under 18 user of this website has volunteered personal data and/or health-related personal data, or that a healthcare professional has volunteered personal data about a patient who is identified as younger than 18, without the given or authorized consent of the holder of parental responsibility over such child, we will promptly, upon relevant notification or request, delete such personal data in accordance with our deletion policy. As noted above, we do not collect personal data unless you provided it to us by including an individual’s age.
CalOPPA Do-Not-Track Notice
Some web browsers incorporate a Do Not Track (DNT) or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his/her online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block that digital service from collecting certain Personal Information about the browser’s user. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason Alnylam does not currently respond to DNT signals. For more information about DNT signals, visit allaboutdnt.com.
For Additional Information
Alnylam Pharmaceuticals, Inc
Attention: Privacy Officer
675 W Kendall Street
Cambridge, MA 02142 USA
For residents in the EU/EEA: Alnylam’s Representative in the Union can be contacted by email at EUdataprivacy@alnylam.com. You can also contact us in writing at:
Alnylam’s EU Privacy Office and the designated Data Protection Officer can also be contacted by email at EUdataprivacy@alnylam.com. You may also contact us in writing at:
ALNYLAM Switzerland GmbH
Attention: Legal department
6300 Zug, Switzerland
For any other questions or concerns, regardless of place of residence, please email us at firstname.lastname@example.org or contact us in writing at:
Alnylam Pharmaceuticals, Inc
Attention: Corporate Communications
675 W Kendall Street
Cambridge, MA 02142 USA
- Privacy Notice for Healthcare Professionals (General Use)
Alnylam Pharmaceuticals and its Affiliates (‘Alnylam’, ‘we’, ‘our’, or ‘us’) is committed to protecting your privacy, and will make all reasonable efforts to protect your personal data (“Personal Data”) in accordance with this Privacy Notice (“Notice”) which applies to the Personal Data that it collects and processes about Health Care Professionals (‘HCPs’) and employees/representatives of Healthcare Organizations (‘HCOs’).
Data Controller and Data Protection Officer (“DPO”)
Each Alnylam entity is acting as a Data Controller for the purposes of this Notice when processing your Personal Data. You can find more information on Alnylam affiliates in Europe and worldwide as well as their establishment and contact details here: http://www.alnylam.com/contact-us/.
Alnylam EU Privacy Office and the designated Data Protection Officer (DPO) are responsible for supervising and monitoring Alnylam’s compliance with applicable EU data protection laws and regulations when processing your Personal Data.
Alnylam EU Privacy Office and the appointed DPO can be contacted at EUdataprivacy@alnylam.com.
Personal Data Alnylam Collects and Source
Alnylam collects and processes Personal Data about you. The types of Personal Data Alnylam collects depend on your relationship with Alnylam as well as applicable laws and regulations and may include the following categories of personal information:
Basic personal details such as identity and contact information (e.g. your name, postal and e-mail address, telephone and mobile phone numbers); Educational and professional details such as qualifications and organizational or institutional affiliations (e.g. title, field of expertise, medical specialty, publications, interests in Alnylam products and your general treatment habits); Economic and Financial and Payments related information, where necessary.
This information may come directly from you or from public or third-party information sources (such as from third-party service providers providing health care professional data and related services).
To better understand and address your interests, and to ensure that the Personal Data that Alnylam maintains and processes about you is accurate, Alnylam may correct or add to any Personal Data you provided directly to Alnylam with Personal Data relating to you that Alnylam receives from other third-party sources.
Lawfulness of Processing
Alnylam processes Personal Data based on one or more of the following legal grounds:
In certain cases, Alnylam may ask for your consent to collect and process your Personal Data. Should you choose to provide your consent, you may later withdraw your consent without giving any reason by contacting us as described in the “How to Reach Us” section. Please note that the withdrawal of consent will not affect processing by Alnylam which has already occurred up to the date of withdrawal.
In other instances, the processing of your Personal Data may be necessary in order to comply with an applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.
In still other instances, Alnylam may process your Personal Data based on Alnylam’s legitimate interests in communicating with you about our products and services, about scientific research and/or about educational opportunities. You have the right to opt-out of all such processing of your Personal Data. You may do so by contacting us as described in the “How to Reach Us” section.
How Alnylam Uses your Personal Data
Alnylam processes Personal Data about you for one or more of the following purposes:
- To perform Alnylam’s obligations under a contract to which you are a party;
- To comply with applicable laws or regulations;
- To publicly disclose any transfers of value made to you, as a Health Care Professional, as required by law or in order to comply with applicable industry standards;
- To provide you with corporate information on Alnylam;
- To provide you with promotional information on Alnylam branded products and services and to carry out promotional activities to you, subject to other applicable regulatory provisions (e.g. e-Privacy Directive);
- To provide to you, on your request, medical and scientific information and updates;
- To handle adverse events reports or quality complaints;
- To send to you invitations to promotional or scientific events e.g. webinars or send you CME invitations;
- To invite you to share with Alnylam your professional insights, to participate in surveys and market research activities; and/or
- To collect and analyze your interests and professional experiences to improve our profile of you as an HCP, including by inferring insights, to provide you with targeted advertising e.g. scientific updates and further enhance the business relationship we have with you (this profile may include your age and gender, medical specialty, prescription habits and others).
The information provided above will be shared via Alnylam’s e-communications channels e.g. by sending you customized or non-customized email and internet communications or to contact you at your office or mobile telephone number (by call or SMS messages), by fax, by the post or through Alnylam’s social media accounts and specific content websites.
Alnylam shall use your Personal Data only for the purposes specified in this section; processing of your Personal Data for any other purpose will be carried out only through prior notification and your specific consent to processing such Personal Data for any possible secondary use or for further purposes.
With Whom Alnylam Shares your Personal Data
Alnylam may transmit Personal Data about you to other Alnylam affiliates worldwide. These affiliates may in turn transmit Personal Data about you to other Alnylam affiliates. Alnylam may also contract with third parties (third party service providers) to perform wholly or partly activities or functions related to the purposes specified above on behalf of Alnylam that involve the use of Personal Data about you. In such cases, Alnylam will require these third parties to comply with applicable data protection laws or regulations and Alnylam company policies to protect the confidentiality and security of the Personal Data that is shared with them. These third parties will be required to agree that they will not use or disclose Personal Data about you except as necessary to provide services to us or perform services on our behalf, or as necessary to comply with applicable laws or regulations.
Moreover, all of Alnylam’s affiliates and third-party data processors acting for and on behalf of Alnylam are required to treat Personal Data in a manner consistent with applicable data protection laws and internal company policies including this Notice.
Some of Alnylam's group companies and/or third-party service providers may be located in countries whose laws may not afford your Personal Data the same level of data protection as the one afforded inside your country. Where your Personal Data will be transferred to third countries, Alnylam will ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such cross-border data transfers; in particular by adopting in its contractual arrangements for cross-border data transfers for Controllers and Processors as well as by implementing appropriate technical and organizational security measures to ensure the security of the processing.
In addition, for the aforementioned purposes, Alnylam transfers some of your Personal Data, according to a strict criterion of relevance, to authorities as well as to other external governmental bodies, having the power to execute checks and investigations towards Alnylam in fulfilment of legal obligations or regulations. These authorities and institutions will act as independent data controllers of their respective processing operations.
To obtain a list of Alnylam’s data processors and categories of data controllers as well as additional information regarding the safeguards Alnylam has in place for cross-border transfers of Personal Data, please contact us using the information provided in the “How to Reach Us” section.
How Alnylam Protects your Personal Data
Alnylam will take reasonable and appropriate physical, administrative and technical safeguards to protect the processing of your Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. In this perspective, the data may be used only by Alnylam’s personnel who need it because of their job or hierarchical position, with confidentiality obligations, which have been assigned a specific role and which have been given appropriate operating instructions.
Your Rights and How to Exercise Them
Individuals in the EU and California consumers have certain data subject rights which may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification or erasure of their Personal Data; (ii) restrict processing, or to object to processing of their Personal Data; and (iii) the right to data portability. If you wish to exercise one of the above-mentioned rights, please refer to the “How to Reach Us” section below.
You also have the right to ask Alnylam not to process your Personal Data for marketing purposes. Alnylam will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise the right to prevent such processing by informing Alnylam at any time that you do not wish to receive such marketing. Where you wish to exercise this right please refer to the “How to Reach Us” section below.
If you do not receive a (timely) response from Alnylam or if you are not satisfied with our response to you, you also have the right to lodge a complaint about the processing of your Personal Data with the appropriate national data protection supervisory authority if you are an EU resident; a list of the national data protection supervisory authorities in Europe can be found here: https://edpb.europa.eu/about-edpb/board/members_en.
How long Alnylam Retains Personal Data
Personal data will only be stored as long as necessary to fulfil the purposes and respective obligations related to such data, for which it was collected, subject to local laws and regulations and legitimate business needs in accordance with Alnylam internal policies.
However, as these purposes and obligations vary from one processing situation to another, Alnylam provides more information on such storage periods in the topic specific privacy notices. Once Personal Data is no longer necessary, Alnylam deletes it or anonymizes it as soon as possible.
For marketing purposes, including any profiling for direct marketing, we will keep your personal data for as long as you want to receive marketing from us. If you decide to opt-out of or withdraw your consent to our marketing, we will no longer use your personal data for this purpose and we will suspend your HCP account for marketing purposes. If the data is not needed for some other purpose (e.g. to carry out our customer relationship), we will delete the data without undue delay or anonymize it as practically possible.
How to Reach Us
You may also reach us via email us at email@example.com or contact us in writing at:
Alnylam Pharmaceuticals, Inc
Attention: Privacy Officer
675 W Kendall Street
Cambridge, MA 02142 USA
EU/EEA residents: For the access, rectification, deletion and restriction of processing and to exercise the right of withdrawal or any other right about the processing of your Personal Data, or if you feel that any of your rights relating to the collection or use of your Personal Data have been violated, you may contact our EU Privacy Office at:
- Data Privacy Notice and Consent Form for Use of Your Personal Data for Electronic Communications Purposes
Alnylam Pharmaceuticals Inc. in the US (“Alnylam”) will act as a data controller and will process your personal data, as specified below, by determining purposes and means of its processing.
Types of Personal Data
Alnylam will process the following Personal Data as applicable: Your contact details, including your name, address, e-mail address, country (altogether “Personal Data”).
Purposes of Use of your Personal Data
Alnylam shall use, process and store your Personal Data in order to send you non-customized email communications in relation to Disease Awareness information in the disease area(s) of your choice and for no other purposes. Any other purpose will require your specific consent.
Scope of Data Flows
For the above-mentioned purposes, your Personal Data will be collected by Alnylam, which is the US legally incorporated entity, and be transmitted to companies of the same group, with the adoption of adequate technical and organizational measures. Alnylam will forward the same data to third parties (individuals and/or companies) acting on its behalf as data processors, including Salesforce Cloud Inc as data storage, which will also be established outside of originating countries.
The list of Data Processors can be requested by sending an email to firstname.lastname@example.org.
The circulation of your Personal Data, considering the dissemination of the same, will reside on US servers. In this case, Alnylam will ensure that appropriate safeguards are in place to legitimize the transmission, such as the adoption of contractual clauses approved by the EU Commission or the data protection national supervisory authority.
Free Provision of Data and Free Consent
You declare that you are eighteen (18) years old or above and legally competent.
You are free to provide such data or your consent to the relevant processing, and your refusal will solely mean that Alnylam will not be authorized to collect and use your Personal Data for sending electronic communications to you.
Personal Data above will be processed both electronically and manually.
Your Personal Data will be reviewed after a 5-year period to ensure your active participation in the receipt of information about your selected disease area(s) of interest. If you would like your data to be deleted prior to the 5-year period, please contact email@example.com.
Exercise of Your rights
You have the right to unsubscribe from receipt of emails in relation to Disease Awareness information in the disease areas of your choice, amend your contact details and other personal data or change your disease areas choice at any time by clicking the unsubscribe link included in future email communications. You can at any time request to be informed about the personal data Alnylam holds about you, access your personal data or ask Alnylam to rectify, erase or block such personal data. For these purposes and for any other questions, please contact Alnylam at the following email address: firstname.lastname@example.org; or by mail to Alnylam’s address:
Alnylam Pharmaceuticals, Inc.
Attention Privacy Office
675 W Kendall Street
Cambridge, MA 02142 USA
You can at any time revoke your consent in writing and submit via email to the address specified above, without having to provide any reason.
In case your data protection-related requests are not handled in a timely and appropriate manner, you have the right to recourse to the competent data protection supervisory authority by lodging a relevant complaint.
To concretely exercise your data protection rights under applicable law in respect to third-party companies that provide services to Alnylam, you can at any time request the list of such companies—full of their contact details—by sending an email to email@example.com.
I have read and understood the content of the above notification and by completing the subscription form to receive updates I expressly consent to the processing of my personal data by Alnylam in the US as well as to the transfer of such data to entities established in the US, in accordance with the terms and mechanisms specified above, taking into consideration that my consent can be withdrawn at any time.
- Direct Marketing / Email Communications Notice
You can elect to receive email updates about developments regarding Alnylam’s products and/or services or about health-related specific topics (e.g. to receive email updates about hereditary ATTR amyloidosis from Alnylam) by completing the relevant electronic form on our website.
In the event of direct marketing of our products and/or services, with any and all means, we will provide you with a method to opt out of or opt-in in receiving further marketing materials as required by law.
If you decide, at any later time, that you no longer wish to receive such email communications from us, you can unsubscribe to any such contact list by using the relevant “Unsubscribe” link within the respective electronic communications channel, or by sending us an email entitled “Unsubscribe from email updates about hATTR amyloidosis” at firstname.lastname@example.org.
- Data Privacy Notice for Use of Personal Data Obtained at Congresses, Symposia and other Events
At a congress in which Alnylam participates as a sponsor and/or exhibitor, at an Alnylam organized symposia or at any other event, Alnylam authorized personnel may request your consent to scan your badge when entering the event venue, including when attending Alnylam sponsored sessions or when visiting Alnylam’s exhibitor booth.
By allowing Alnylam to scan your badge in the above circumstances, you express your consent for Alnylam and its Affiliates worldwide (collectively referred to as “Alnylam”) to receiving your Personal Data (such as name, surname, address, e-mail address, phone numbers, medical specialty), which you voluntarily provided to the congress organizer, when you registered for the venue, and further processing it for marketing and compliance purposes, in accordance with applicable data protection laws, industry codes and Alnylam’s policies.
We will also further process your personal data, by relying on Alnylam’s legitimate business interests to comply with industry codes and standards and to communicate with you to provide you with information about Alnylam’s medicinal products and services, about medical and scientific research updates and/or about educational opportunities, that might be of interest to you, as well as to invite you to relevant promotional activities as further described in the specific Privacy Notice for Healthcare Professionals (General Use).
Scanning of your badge is voluntary; you are not required to agree to it and it will not affect your participation to the event or any specific session. If you choose at the time to consent to the scanning of your badge, you are able to withdraw your consent at any later time, without giving any reason, by contacting us at email@example.com or is you are a resident of Europe at EUdataprivacy@alnylam.com.