Privacy Policy
Last Updated: February 16, 2023
This Privacy Policy (“Policy”) applies to personal information collected through sublocade.com and other websites or applications that link to this Policy (collectively, the “Services”). This Policy describes the processing of personal information by Indivior Inc., which is ultimately owned by Indivior PLC (together, with all other Indivior PLC owned entities, the “Indivior Group”). All references to “Indivior,” “us,” “our,” or “we” shall mean the Indivior Group.
Please note that from time to time Indivior may operate other websites, applications, or services that do not link to this Policy and may be subject to separate privacy policies, which will be provided separately or made available via those sites, applications, or services. This Policy does not govern personal information collected via websites that do not link to this Policy, and you should instead refer to the privacy policies made available in connection with those sites, applications, or services. (For more information about Indivior’s general data processing activities, including for information collected through Indivior.com, please refer to Indivior’s Global General Privacy Policy and Notice available here.)
This Policy is part of and incorporated into the Terms of Use found at http://www.indivior.com/terms-of-use/, which is a legally binding agreement between you and Indivior.
We may update this Policy from time to time. Therefore, we ask you to check this Policy occasionally to ensure that you are aware of the most recent version. We will notify you any changes where we are required to do so.
For purposes of this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household. For purposes of this Policy, “personal information” should be understood to include “personal data” and similar terms under applicable privacy laws.
What Information Do We Collect and How Do We Use It?
Indivior collects certain personal information that you provide to us voluntarily. We also collect personal information about you automatically when you access the Services, such as through the use of website “cookies”. Additionally, in some cases Indivior may obtain personal information from publicly available sources; healthcare provider directories; events management agencies; and vendor agencies, including market research and media agencies. In the preceding 12 months, we have collected the following categories of personal information:
- Identifiers (e.g., first and last name, mailing address, email address, phone number, IP address)
- Demographic information (e.g., date of birth, age, gender)
- Internet and network activity information (e.g., information about your Internet service provider; computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting; details about your use of the website and browsing history, such as access time, pages viewed, search terms entered, and URLs clicked on)
- Geolocation data (e.g., the approximate location of your computer or device)
- Inferences drawn from the information described in this section to better understand our consumers and to help improve products and services
- Other information you may provide to us (e.g., when you fill out a questionnaire, sign up for a survey, or otherwise interact with us)
We may use personal information for the following purposes:
- To provide and administer our products and services
- To develop, update, improve, and refine our products and services
- To provide you more relevant advertising on and off our Services, including to show you targeted advertising on our websites and on third-party websites you may visit
- To send you marketing communications, including information about specific products and other marketing and promotional materials
- To communicate with you, including responding to your queries or requests
- To help us track the way you use our website
- To help us understand our consumers
- To help us understand the effectiveness of our advertising and marketing campaigns
- To invite you to relevant events and participate in research or surveys as needed
- To comply with our legal obligations (including any investigations or requests from relevant authorities)
- To defend or make legal claims, including to protect our rights or the rights of another party
- In connection with research about our products, market, and business
- As reasonably needed in connection with any proposed or actual sale or transfer of any part of our business
- Or as otherwise described to you at the time we collect your personal information
Please also note that our Services collect personal information through the use of cookies (and similar technologies) for the purposes above.
We may also deidentify personal information so that it cannot be used to identify you and is no longer considered personal information under applicable laws. We will maintain and use this data only in deidentified form and will not attempt to re-identify the data.
Disclosing Your Personal Information
In the preceding 12 months, we have disclosed personal information for the business purposes described above to the following categories of recipients:
- Service providers who provide services or functions for Indivior or process information on our behalf. For example, this may include hosting our Services, storing our data, managing databases, performing analyses, or sending communications for us, among other services. These parties may receive the following categories of information: identifiers, demographic information, internet and network activity information, geolocation data, inferences, and other information you provide.
- Other Indivior Group companies. These companies may receive the following categories of information: identifiers, demographic information, internet and network activity information, geolocation data, inferences, and other information you provide.
Please note that we may also disclose personal information in the following circumstances:
- In connection with a merger, acquisition, or other transfer of some or all of the Indivior business or its assets. In the event Indivior, or its assets, is bought or sold, personal information may be included among the transferred business assets. In this case, a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information will be provided. This may involve disclosing any or all of the categories of personal information we collect.
- Personal information may also be disclosed to government authorities or other relevant parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities. This may involve disclosing any or all of the categories of personal information we collect.
We also share your information with third parties who may use your information for their own purposes, including for purposes of their and our marketing purposes and for purposes of providing targeted advertising. These disclosures may be considered a “sale” or “sharing” of personal information under applicable privacy laws. In the past 12 months, we have “sold” or “shared” personal information to the categories of recipients listed below:
- Third-party partners, including providers of analytics and targeted advertising. These companies may receive the following categories of information: identifiers, demographic information, internet and network activity information, geolocation data, and inferences.
- Social media partners, including for analytics and targeted advertising. These companies may receive the following categories of information: identifiers, demographic information, internet and network activity information, geolocation data, and inferences.
We do not knowingly sell or share the personal information of consumers under 16 years of age, nor do we use or disclose sensitive personal information in connection with the Services.
Your Privacy Rights
You may have certain rights with respect to your personal information, which will depend on various factors including where you live and the applicable laws in your jurisdiction. Some rights may be subject to exceptions. For your own protection and that of others, we may need to verify your identity before you exercise such rights. Where applicable under local law, these rights may include:
- Right to know and access specific pieces of personal information, including to request that we disclose certain information to you about our collection, use, and disclosure of your personal information, or to request access to the specific pieces of information we have collected about you.
- Right to request deletion of personal information
- Right to request correction of personal information
- Rights to opt out of sales, sharing, and targeted advertising (as those terms are defined under applicable laws)
- Right to opt out of certain profiling activity, where profiling results in legal or similarly significant impacts on consumers
- Right not to be discriminated against for exercising your rights
Exercising Your Rights
To opt out of sales, sharing, and targeted advertising, you may do so by clicking the Do Not Sell or Share My Personal Information link at the bottom of the websites linking to this Policy and following the instructions. Where required, we also honor requests to opt-out submitted via privacy preference signals recognized under applicable local law, such as the Global Privacy Control (GPC). For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/.
To submit a request to know, access specific pieces of information, or correct personal information, you may contact us using one of the following options:
- You may submit a request via email to Privacy@indivior.com
- Or you may call our toll-free number at 877-820-1280
Only you, or an agent that you authorize to act on your behalf, may submit a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access to the specific pieces of personal information we hold about you twice within a 12-month period. The verifiable consumer request must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. For example, you should clearly state which right you wish to exercise.
- For requests from authorized agents, agents must provide proof that you gave the agent signed permission to submit the request on your behalf (or, if applicable, that you provided the agent with power of attorney).
In order to verify your identity, we may respond and request additional information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person. Depending on the type of request you submit, we may ask you to provide two or more specific pieces of information about you, which may include, among other details, your name or address.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. When verifying a request from an authorized agent, we may also require that the consumer either verify their own identity directly with us or confirm that they provided the authorized agent permission to submit the request.
We will only use the personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Where applicable under local law, you may also contact us using the contact details above to appeal any decision we make relating to your request to exercise your rights.
Response Timing and Format
We will confirm receipt of a request within ten days. We endeavor to respond to verifiable consumer requests within 45 days of its receipt. If we require more time (up to 90 days total), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at our option.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
Privacy Policy and Notice for California Residents
California law requires that we describe the personal information we collect about California consumers, including by identifying specific categories of data. Indivior collects certain personal information that you provide to us voluntarily. We also collect personal information about you automatically when you access the Services, such as through the use of website “cookies”. Additionally, in some cases Indivior may obtain personal information from third party sources, including publicly available sources; healthcare provider directories; events management agencies; and vendor agencies, including market research and media agencies.
Categories of Personal Information: We have collected the following categories of personal information in the context of the Services in the past 12 months:
- Identifiers (e.g., first and last name, mailing address, phone number, IP address)
- Demographic information (e.g., date of birth, age, gender)
- Internet and network activity information (e.g., information about your Internet service provider; computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting; details about your use of the website and browsing history, such as access time, pages viewed, search terms entered, and URLs clicked on)
- Geolocation data (e.g., approximate location of your computer or device)
- Inferences drawn from the information described in this section to better understand our consumers and to help improve products and services
- Other information you may provide to us (e.g., when you fill out a questionnaire, sign up for a survey, or otherwise interact with us)
How We Use Personal Information: We may use personal information for the following purposes:
- To provide and administer our products and services
- To develop, update, improve, and refine our products and services
- To provide you more relevant advertising on and off our Services, including to show you targeted advertising on our websites and on third-party websites you may visit
- To send you marketing communications, including information about specific products, discount vouchers, and other marketing and promotional materials
- To communicate with you, including responding to your queries or requests
- To help us track the way you use our website
- To help us understand our consumers
- To help us understand the effectiveness of our advertising and marketing campaigns
- To invite you to relevant events and participate in research or surveys as needed
- To comply with our legal obligations (including any investigations or requests from relevant authorities)
- To defend or make legal claims, including to protect our rights or the rights of another party.
- In connection with research about our products, market, and business
- As reasonably needed in connection with any proposed or actual sale or transfer of any part of our business
- Or as otherwise described to you at the time we collect your personal information
How Long We Retain Personal Information: We will retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was obtained, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation and we believe the personal information is relevant. To determine the appropriate retention period for personal information we consider: the necessity to retain the personal information; 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; whether we can achieve these purposes through other means; and the applicable legal, regulatory, tax, accounting, or other similar requirements.
How We May Disclose Personal Information: We may disclose your personal information to third parties as described in the “Disclosing Your Personal Information” section of the Policy above. In the preceding 12 months, we have disclosed personal information for the business purposes described above to our service providers and other Indivior Group companies. These parties may receive the following categories of information: identifiers, demographic information, internet and network activity information, geolocation data, inferences, and other information you provide.
Please note that we may also disclose personal information in connection with a merger, acquisition, or other transfer of some or all of the Indivior business or its assets or to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities. This may involve disclosing any or all of the categories of personal information we collect.
We also share your information with third parties who may use your information for their own purposes, including for purposes of their and our marketing purposes and for purposes of providing targeted advertising. These disclosures may be considered a “sale” or “sharing” of personal information under California law. In the past 12 months, we have “sold” or “shared” personal information to third-party partners/providers and social media partners, including for analytics and advertising. These companies may receive the following categories of information: identifiers, demographic information, internet and network activity information, geolocation data, and inferences.
We do not knowingly sell or share the personal information of consumers under 16 years of age, nor do we use or disclose sensitive personal information in connection with the Services.
To opt out of sales or sharing, you may do so by clicking the Do Not Sell or Share My Personal Information link at the bottom of the websites linking to this Policy and following the instructions. Where required, we also honor requests to opt-out submitted via privacy preference signals recognized under applicable local law, such as the Global Privacy Control (GPC). For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/. For more information about other rights you may have, please refer to the “Your Privacy Rights” section of the Policy above.
Contacting Us
If you have any questions or comments about this Privacy Policy and Notice or otherwise wish to contact us, you may do so by mail at:
Indivior Inc.
10710 Midlothian Turnpike
North Chesterfield, VA 23235
Attn: Legal Department
You may also contact us by email at Privacy@indivior.com
Or you may call our toll-free number at: 877-820-1280