In the regular course of business, Gilead interacts and communicates directly with health care professionals, customers, clinical trial participants, consumers, business partners, regulatory authorities, and others. Through these interactions and communications, Personal Information may be provided to Gilead and processed electronically and/or manually. Gilead respects individual privacy and values the confidence of such individuals. This Privacy Statement sets forth Gilead's privacy principles with respect to Personal Information, including the implementation of privacy procedures and technical security measures to keep Personal Information private and secure, which Gilead follows in its normal course of business. Gilead will collect, use and disclose Personal Information in accordance with applicable privacy or data protection laws and the principles outlined in this Privacy Statement.

Scope

This Privacy Statement applies to Personal Information received by Gilead (including Personal Information received by third-party organizations or individuals acting as Agents of Gilead) from health care professionals, customers, clinical trial participants, consumers, business partners, regulatory authorities, and others, in any format, including electronic or paper, as part of Gilead's business operations. This Privacy Statement does not apply to Personal Information received by Gilead (including Personal Information received by third-party organizations or individuals acting as Agents of Gilead) as part of Gilead's management of its employees, contractors, or other individuals who perform work for, or on behalf of Gilead. This Privacy Statement does not apply to Personal Information collected by Gilead Websites as the Gilead Website Privacy Statement would then be applicable.

Definitions

For the purposes of this Privacy Statement, the following definitions shall apply:

"Agent" means any third party that collects and/or uses Personal Information under the instruction of, and solely for, Gilead or to which Gilead discloses Personal Information for use on Gilead's behalf.

"Gilead" means Gilead Sciences, Inc., its successors and wholly owned subsidiaries.

"Gilead Website(s)" means websites controlled by Gilead and subject to the Gilead Website Privacy Statement.

"Personal Information" means any information or set of information that identifies or is used by or on behalf of Gilead to identify an individual. Examples of Personal Information include an individual's name, postal address, e-mail address, and telephone number. Personal Information does not include any information that is anonymized, or non-personal information that has not been combined with Personal Information to allow identification of an individual.

""Sensitive Personal Information" is a Gilead-defined subset of Personal Information. Sensitive Personal Information includes information such as government unique identifier or financial information, race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns health, sexual orientation, or criminal allegations (convictions or otherwise).

Gilead Privacy Principles

NOTICE: The collection, use, and disclosure of Personal Information in the business context is essential to the conduct of many of Gilead's business functions. Gilead may collect Personal Information from individuals directly and/or from third parties, where Gilead has provided notice to individuals of data collection, and/or obtained the individuals’ consent to do so or as otherwise required or permitted by law.

Where Gilead collects Personal Information directly from individuals, Gilead will inform them about the purposes for which it collects and uses their Personal Information, the types of third parties with which Gilead shares Personal Information, and the choices and means, if any, Gilead offers individuals for limiting the use or disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Gilead, or as soon as practicable thereafter, and in any event before Gilead uses or discloses the information for a purpose other than that for which it was originally collected. Where prescribed by applicable local laws, consent will be obtained for such disclosures. In these circumstances, the form of consent that Gilead seeks, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations the individual might have in the circumstances.

For example, Gilead may collect Personal Information for the purposes of disease management, education, decision support systems, requests for product information, clinical trials, registration for Gilead programs, customer service support, marketing or Gilead surveys. Individuals should not provide Gilead with any Personal Information that is not specifically requested. Where Gilead receives Personal Information from its subsidiaries, affiliates, or other entities, it will use or disclose such Personal Information in accordance with the notices provided at the time the Personal Information was collected, the limitations on such use or disclosure authorized or consented to by the individuals to whom such Personal Information relates, or as instructed, by such individual at a later date.

Gilead may consolidate the Personal Information of individuals who provide such Personal Information to Gilead consistent with the purposes for which the Personal Information was collected. In addition, Gilead may consolidate information in a non-identifiable form (aggregated/anonymized data) to help Gilead better design Gilead products and services, to enhance Gilead's research activities, and to facilitate other business functions.

CHOICE: As appropriate, Gilead will offer individuals the choice to consent to their Personal Information (a) being disclosed to a non-Agent third party, and/or (b) being used for a purpose other than the purpose for which it was originally collected and/or consented to by the individual, except as otherwise provided by law. Gilead may be prevented from providing certain services to individuals who do not choose to allow the use or disclosure of their Personal Information. Gilead will provide more specific notice of the choice mechanisms, and the consequences for exercising such choice, at the time that Gilead collects Personal Information.

Notwithstanding the foregoing, Gilead may share, subject to applicable laws and regulations, Personal Information with Agents who assist Gilead with its business activities related to the purposes for which the information was provided. Such Agents may include, but are not limited to, service providers that administer Gilead's email subscriptions and requests for information, or provide services. Gilead requires such Agents to keep Personal Information confidential and to use or disclose Personal Information only to perform functions for Gilead and in accordance with Gilead's instructions and this Privacy Statement.

For Sensitive Personal Information, Gilead will give individuals the opportunity to affirmatively and explicitly authorize or consent to the disclosure of their Sensitive Personal Information to a non-Agent third party or the use of their Sensitive Personal Information for a purpose other than the purpose for which it was originally collected or authorized by the individual.

Gilead may disclose Personal Information, without obtaining the individual’s consent, in order to respond to authorized information requests from government authorities; or when otherwise required or permitted by law and/or to comply with a judicial proceeding, court order, or legal process.

Gilead may also use or disclose Personal Information, in accordance with applicable law: (i) in connection with a contemplated or actual reorganization of its business; (ii) when seeking financing or in connection with an assignment, sale, or other transaction involving the disposal of all or part of its business or assets, including for the purpose of permitting the parties to conduct due diligence so as to determine whether a transaction should proceed; and (iii) in association with the transaction. In any assignment or sale, the assignee or purchaser may use and disclose Personal Information collected by Gilead for substantially the same purposes as described in this Privacy Statement. Such transfer may be subject to individuals' consent when required by applicable law.

Gilead will not disclose your Personal Information to third parties except as otherwise stated in this Privacy Statement.

DATA INTEGRITY: Gilead will use Personal Information only in ways that are compatible with the purposes for which it was collected, or consented to by the individual. Gilead will have appropriate steps in place to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. Gilead will only store Personal Information for as long as it is needed to fulfill the purposes for which it was collected, subject to applicable data retention periods imposed upon Gilead by applicable law.

TRANSFERS TO AGENTS: Gilead will obtain assurances from its Agents that they will safeguard Personal Information consistent with this statement. An example of appropriate assurances that may be provided by Agents include a contractual obligation that the Agents provide at least the same level of protection as is required by Gilead's privacy principles set out in this Statement. Where Gilead has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Privacy Statement, Gilead will take appropriate steps to prevent or stop the use or disclosure.

In addition, Gilead may send Personal Information outside of your country for the purposes set out above, including for process and storage by Agents in connection with such purposes. The laws of third countries to which Gilead may send Personal Information might not be equivalent to the laws in your country of residence, however please be assured that Gilead takes steps to ensure that your privacy is protected, such as by implementing contractual controls, or seeking your consent, where required by law. However, to the extent that any Personal Information is sent out of your country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

ACCESS AND CORRECTION: Access to Personal Information is limited to a restricted number of Gilead employees whose duties reasonably require such information, Agents with whom Gilead contracts to carry out business activities for Gilead, and, with an individual's consent, certain companies with which Gilead may conduct joint programs. Gilead trains its employees about the importance of privacy and how to handle and manage Personal Information appropriately and securely. Personal Information handled by Gilead Agents, or companies with which Gilead may conduct joint programs, is governed by this Privacy Statement.

Upon written request, Gilead will grant individuals access to Personal Information that it holds about them, subject to any legal restrictions. In addition, Gilead will permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, subject to certain exceptions provided by law. In some instances, applicable law or regulatory requirements allow or require Gilead to refuse to provide some or all of an individual's Personal Information. In addition, Personal Information may have been destroyed, erased or made anonymous in accordance with Gilead's record retention obligations and practices. In the event that Gilead cannot provide an individual with access to his/her Personal Information, Gilead will endeavor to provide the individual with an explanation, subject to any legal or regulatory restrictions.

Individuals may, at any time revoke their consent to collect, use or disclose their Personal Information. All requests to revoke consent should be progressed with Gilead as directed below under ENFORCEMENT.

SECURITY: Gilead uses physical, technical, and managerial safeguards to keep your Personal Information protected from unauthorized access, disclosure, alteration, and destruction. Such measures may include, but are not limited to the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, Gilead cannot absolutely guarantee the security of your Personal Information.

ENFORCEMENT: Gilead will conduct periodic compliance audits of its relevant privacy practices to verify adherence to this Privacy Statement.

Gilead will investigate and attempt to resolve complaints, disputes and requests to revoke consent regarding collection, use and disclosure of Personal Information in accordance with the principles contained in this Privacy Statement. Complaints, disputes and/or requests to revoke consent to the collection, use or disclosure of Personal Information should be sent to Gilead’s address, provided below under “Contact Information”. Complaints or disputes that cannot be resolved between Gilead and the complainant will be handled through an independent dispute resolution process as described below.

Independent Recourse Mechanism

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.  

International Data Transfers from the EEA to Third Countries

Gilead uses Standard Contractual Clauses approved by the European Commission when transferring personal information from Gilead affiliates and subsidiaries or Agents in the European Economic Area ("EEA") to countries outside the EEA including the USA.

Limitation on Application of Principles

Adherence by Gilead to these principles may be limited (i) to the extent required to respond to a legal or ethical obligation, and (ii) to the extent expressly required by an applicable law, regulation, or rule.

Contact Information

Any questions or concerns regarding this Privacy Statement, or the use or disclosure of Personal Information and requests to opt-out of future communications from Gilead or a particular Gilead program should be directed to Gilead by telephone at +1 (800) GILEAD5 or +1 (650) 522-5775 or by e-mail at privacy@gilead.com. Alternatively, letters may be sent to the following address:

Gilead Sciences, Inc.
Attn: Privacy
333 Lakeside Drive
Foster City, CA 94404
USA

All communications to Gilead should include the individual's name and contact information (such as e-mail address, phone number, or mailing address), and a detailed explanation of the request. E-mail requests to delete, amend, or correct Personal Information should include "Deletion Request" or "Amendment/Correction Request", as applicable, in the subject line of the e-mail. Gilead will endeavor to respond to all reasonable requests in a timely manner, and in any case, within any time limits prescribed by applicable local law.

Changes to Gilead Privacy Statements

Gilead reserves the right to amend this Privacy Statement from time to time to reflect technological advancements, legal and regulatory changes, and Gilead's business practices, subject to applicable laws. If Gilead changes its privacy practices, an updated version of this Privacy Statement will reflect those changes. Gilead will provide notice of such changes by updating the effective date listed on this Privacy Statement. It is your responsibility to check this Privacy Statement frequently to view any amendments. Your continued interaction with Gilead, in the activities covered above, will be subject to the then-current Privacy Statement.

Last Updated: 18 November, 2016