Safe Harbor Privacy Policy

Janssen Pharmaceuticals, Inc., and its affiliates are members of the Johnson & Johnson family of companies and are strongly committed to protecting the privacy of those who entrust us with their personal information. Our employees, and all those who do business with us, trust and expect that we will protect their personal information in accordance with the promises we make. In furtherance of our commitment, Janssen Pharmaceuticals, Inc., has certified to the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework with respect to personal data processed as part of our human resources activities and healthcare provider information management. Janssen Pharmaceutical, Inc.’s affiliates have certified to the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework with respect to personal data processed as part of our human resources activities and clinical research activities. Accordingly, Janssen Pharmaceuticals, Inc., and its affiliates adhereto the Safe Harbor privacy principles and frequently asked questions, as separately agreed to by the US Department of Commerce and the European Commission, and the Federal Data Protection and Information Commissioner of Switzerland.

Scope

This Safe Harbor Privacy Policy sets forth how Janssen Pharmaceuticals, Inc., handles personal data transferred to the United States from countries in the European Economic Area (EEA) and Switzerland that are collected or received in managing our workforce and managing healthcare provider information; and how Janssen Pharmaceutical, Inc.’s affiliates handle personal data transferred to the United States from countries in the EEA and Switzerland that are collected or received in managing our workforce and clinical research activities.

Definitions

The following terms are used throughout this document and are defined here for clarification.

Agent

"Agent" means a third party that processes personal data solely on behalf of and under the instructions of Janssen Pharmaceuticals, Inc., and its affiliates.

Personal Data

"Personal data" means any information or set of information that identifies or can reasonably be used to identify an individual. Personal data do not include information that is encoded or anonymized, or publicly available information that has not been combined with nonpublic personal information.

Sensitive Personal Data

"Sensitive personal data" means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. Information will be treated as sensitive personal data where it is received from a third party that treats and identifies it as sensitive.

Privacy Principles

The following privacy principles apply to the collection, use, and disclosure of personal data by Janssen Pharmaceuticals, Inc., and its affiliates in conducting human resources and clinical activities.

Notice

Janssen Pharmaceuticals, Inc., and its affiliates will inform individuals about the purposes for which we collect and use personal data about them, how to contact us, the types of nonagent third parties with whom we may share personal data, and any ways that individuals may limit the use and sharing of such data. This notice will be provided when individuals are first asked to provide personal data or as soon thereafter as is practicable.

Choice

Janssen Pharmaceuticals, Inc., and its affiliates will offer an individual the opportunity to choose (opt out) whether personal data are (a) shared with a nonagent third party or (b) used for a purpose other than that for which the data were originally collected or subsequently authorized by the individual.

Janssen Pharmaceuticals, Inc., and its affiliates will give an individual an affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual.

Access

Janssen Pharmaceuticals, Inc., and its affiliates will provide individuals with reasonable access to personal data about them and they may request the correction or amendment of personal data that they demonstrate to be incorrect or incomplete.

Transfers to Agents

Janssen Pharmaceuticals, Inc., and its affiliates will only transfer personal data to an agent where the agent has provided assurances that the agent provides at least the same level of privacy protection as is required by these privacy principles. Where we have knowledge that an agent is using or sharing personal data in a way that is contrary to these principles, Janssen Pharmaceuticals, Inc., and its affiliates will take reasonable steps to prevent or stop such processing.

Onward Transfer

Janssen Pharmaceuticals, Inc., and its affiliates will only transfer personal data to a nonagent third party where consistent with the notice provided to the individuals who are the subject of the data and any consent that those individuals have given.

Information Integrity

Janssen Pharmaceuticals, Inc., and its affiliates will only use and share personal data about individuals in a way that is consistent with the purposes for which the data were collected or subsequently authorized by those individuals. To the extent necessary for those purposes, Janssen Pharmaceuticals, Inc., and its affiliates will take reasonable steps to ensure that the data are accurate, complete, and current.

Information Security

Janssen Pharmaceuticals, Inc., and its affiliates will take reasonable precautions to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Enforcement

Janssen Pharmaceuticals, Inc., and its affiliates have put in place mechanisms to verify our ongoing adherence to these privacy principles. We encourage individuals covered by this Policy to raise any concerns that they have about the way that we process their personal data by contacting us at the address below, and we will do our best to resolve them. We have also agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel and to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.

Limitation on Scope of Principles

Adherence by Janssen Pharmaceuticals, Inc., and its affiliates to these privacy principles may be limited to the extent required to meet a legal, governmental, national security, or public interest.

How to Contact Us

Please contact us with any questions about our Safe Harbor certification practice.

Johnson & Johnson Health Care Compliance & Privacy
1125 Trenton-Harbourton Road
Titusville, New Jersey 08560
Phone: 1-609-730-7966
Attn: Senior Manager, Privacy Compliance Pharmaceuticals Group
privacy5@its.jnj.com

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor. When we do, we will also revise the "last updated" date at the bottom of this Policy. For material changes to this Policy, we will notify individuals by placing a notice on the following Web site: http://www.janssenpharmaceuticalsinc.com.

This Safe Harbor privacy policy was last updated on December 5, 2011.