Privacy Policy

This Privacy Policy (“Policy”) explains how Deerfield Management Company, L.P., a Delaware limited partnership (“we”,“our”, “us” or “Deerfield”) collects, uses, maintains, and shares your information in connection with your relationship with us. This Policy applies to visitors to our website located at www.deerfield.com (the “Site”), including individuals who sign up to attend our events through the Site or any other site or application (“Site Visitors”); survey participants (“Survey Participants”) and consultants (“Consultants”) we engage to support the investment management services we provide (referred to as our “Services”) and our other activities; and any other individuals with whom we interact for the purposes of providing our Services. This Policy also applies to information collected by Deerfield about applicants in connection with opportunities for employment at Deerfield, its affiliates, or its portfolio companies (“Applicants”). Each Site Visitor, Survey Participant, Consultant, and Applicant may be referred to herein as “you.”

Please note that Applicants and Consultants who are engaged directly with a Deerfield portfolio company are covered by such company’s own privacy notice. Applicants and Consultants that have questions about how such companies may collect or use your Personal Information should contact such companies directly. If you are an investor or otherwise affiliated with us, please refer to the introductory information provided to you by us or contact us as outlined below for additional assistance.

You are agreeing to the terms of this Privacy Policy by using or otherwise accessing the Site; agreeing to participate in one of our surveys or to work with us as a consultant; applying for employment with or through us; or by otherwise interacting with our Services. This Policy constitutes a legal agreement between you and Deerfield. If we make changes to this Policy, we will update the effective date listed at the top of this page. Any change will be effective immediately upon posting on the Site. You should review this Policy each time you access the Site or engage with us as a Consultant, Survey Participant, or Applicant to see the most recent version. YOUR CONTINUED USE OF THE SITE OR ENGAGEMENT WITH US AS A CONSULTANT, SURVEY PARTICIPANT, OR APPLICANT FOLLOWING THE POSTING OF ANY CHANGES TO THIS POLICY CONSTITUTES ACCEPTANCE OF SUCH CHANGES.

Please note that, depending on your relationship with us or our affiliated companies, additional or other Deerfield privacy policies may be relevant to you. You may contact us as outlined in the “Contact Us” section, below, if you require assistance or if you have any questions regarding our privacy practices.

Information We Collect

Depending on your relationship with us, we may collect the following categories of information about you:

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How We Use Your Information

Deerfield may use the personal information we collect about you for the following purposes:

• To better understand general usage of the Site and to improve the Site and/or our Services;
• To respond to your requests, such as to send you publications or other information;
• For internal business purposes, such as auditing, data analytics, and research to create, develop, operate, deliver, and improve our Site, our Services, and our communications;
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of personal information, where reasonably necessary and proportionate;
• To provide you with information and materials regarding activities, programming, properties, and other aspects of Deerfield and our affiliates, including via publications, newsletters, and emails for informational purposes;
• To defend our interest in actual or threatened legal proceedings or with respect to compliance inquiries or investigations; or
• To fulfill our legal obligations, such as to uphold our responsibilities to Survey Participants and Consultants under applicable agreements.
• For Applicants, we may use information provided to consider you for employment at Deerfield or our affiliates or, where applicable, with our portfolio companies, and to maintain and improve our recruiting processes. This may include, for example:
  • Receiving, reviewing, and replying to your application;
  • Verifying the information you or others have provided and checking your references;
  • Assessing your suitability for the opportunity you have applied for;
  • Communicating with you about the interview and recruiting process;
  • Preparing an offer letter, if your application is successful;
  • Suggesting potentially suitable opportunities for you at Deerfield, our affiliates, or at our portfolio companies in addition to the company or position you may have applied for or expressed interest in;
  • Managing and improving our recruiting processes;
  • Analyzing recruiting metrics; and
  • Creating and submitting reports as required by applicable law.

How We Disclose Your Information

Deerfield may disclose your personal information with certain categories of third parties in a limited number of circumstances, including:

• To our service providers, such as to enhance the Site and the Services Deerfield provides, and to assist us in upholding our responsibilities under our agreement(s) with you;
• To respond to a subpoena or court order, judicial process or regulatory inquiry;
• To protect or defend against fraud, lawsuits, claims or other liabilities;
• To protect the security of our systems, or to protect our rights or property;
• In connection with a proposed or actual sale, merger, or transfer of all or a portion of Deerfield’s business;
• To otherwise assist Deerfield in offering Services; and
• For the distribution of publications, newsletters, or other information that Deerfield believes may be useful to you.
• For Applicants, we may additionally share your Identifiers, Professional or Employment Information, and Education Information with our portfolio companies where we act on such companies’ behalf for recruiting or employment onboarding purposes. We may also share this Personal Information with our third-party service providers that provide services such as recruiting assistance, background checks, processing, and similar services.
• For Consultants, we may also share your Identifiers, Professional or Employment Information, and Education Information in a limited number of additional circumstances, such as disclosure to service providers with which Deerfield works to enhance its internal databases that it uses in connection with its Services.

Your Rights and Choices

Based upon where you reside, certain choices and rights with regards to your personal information may be available to you, including the right to request that we:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties to which we disclose personal information;
• Provide you access to and/or a copy of personal information we hold about you;
• Correct or update personal information we hold about you;
• Delete personal information we have about you;
• Restrict or object to certain uses of your information; or
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

Please note that certain information may be exempt from such requests under applicable law. We are required by law to take reasonable steps to verify your identity prior to responding to your request to exercise the above rights.

We may verify your request by asking for information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and as permitted by applicable law. Where required by applicable law, we will notify you if we reject your request, and notify you of the reasons we are unable to honor your request.

To exercise any of these rights, please contact us using the information as provided in the “Contact Us” section below. California residents have the right to use an authorized agent on your behalf to exercise one or more of the privacy rights discussed above in this Section.  If you are an authorized agent acting on behalf of an individual to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the individual. You can make a request on the individual’s behalf by contacting us as set forth below in the “Contact Us”section with supporting verification information and proof of your own identity.

Please note that we do not sell personal information or share/process personal information for targeted advertising purposes.

Privacy Information for California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

Throughout this Policy, we discuss in detail the specific categories of personal information we collect from and about you. We provide additional information required by the CCPA below.

Information We Collect and How We Disclose It

The information that we have collected about California residents, and the sources from which we have collected it, are described above in “Information We Collect.” Our business or commercial purpose for collecting personal information is described above in “How We Use Your Information.”

Deerfield has collected and disclosed the following categories of personal information about consumers for a business purpose in the preceding 12 months:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, or other similar identifier.
• Characteristics of protected classifications under California or federal law. In some cases, we may collect some limited sensitive personal information about you, such as by asking event attendees to voluntarily provide information as to whether they require any special assistance or accessibility features. This information is only used for the limited purposes for which it is collected.
• Sensitive personal information. In some cases, we may collect some limited sensitive personal information about you, such as by asking event attendees to voluntarily provide information about any dietary restrictions that they may have, or in connection with Applicants and Consultants. This information is only used for the limited purposes for which it is collected or as otherwise provided in this Policy.
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, including information regarding a consumer’s interaction with our Site, such as IP address, browser type and version, and pages visited on our Site.
• Audio, electronic, visual data, such as photographs and audio/visual recordings during events we co-sponsor. We may also collect audio recordings from internal Deerfield activities, subject to additional notices that we provide in advance of those collection activities.
• Professional or employment-related information. We generally do not collect professional or employment-related information, except in some limited circumstances, such as with respect to our employees and staff, or the employees and staff of our affiliates.
• Education information, such as graduating institution, and additional educational criteria necessary to select candidates for employment.
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Your Rights as a California Resident

California residents may make certain requests about their personal information under the CCPA as set forth in “Your Rights and Choices” section above. In the limited circumstances that we process sensitive personal information as defined in the CCPA (e.g., log-in or biometric information), we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

“Shine the Light” Law. California's “Shine the Light” law (Civil Code Section§ 1798.83) permits users of the Services that are California residents to request, once a year, certain information regarding our disclosure of “personal information” to third parties for their “direct marketing purposes” (as both terms in quotes are defined in the Shine the Light law). However, a company is not required to provide this information where it adopts and discloses a policy of not disclosing “personal information” to third parties for their “direct marketing purposes:” (1) unless the resident first affirmatively agrees, or (2) if the resident has exercised an option that prevents that information from being disclosed. We maintain such a policy. To opt out, please submit a written request to us using the contact information below in the “Contact Us” section below.

Non-Discrimination. You will not receive any discriminatory treatment by us for exercising your privacy rights.

Online Tracking

Our Site does not currently recognize automated web browser tracking method signals, such as “do not track” instructions. You can change your privacy preferences regarding the use of cookies and other technologies through your browser, including blocking all cookies; however, blocking all cookies may affect your use of the Site and other websites and services online, and may prevent you from using all the features and elements of the Site and other websites and services.

Links to Other Websites and Services

Our Services may contain links to, or advertisements concerning, other websites. Other websites may also reference, advertise, or link to Deerfield. Deerfield is not responsible for the privacy practices or the content of such other websites. You should check the applicable privacy policy of any website you access through the Services.

Data Security Measures

Deerfield takes the security of personal information provided to us very seriously, and we have implemented commercially reasonable physical, electronic, and procedural safeguards to try to ensure the protection of your personal information. We only keep your personal information for as long as required to provide you with the services you request, for the purposes outlined in this Policy, and for any legal purpose for which we are obligated to keep the information unless a longer retention period is mandated by our customary record retention policies.

We endeavor to restrict access to your personal information (if any) to those employees and representatives who need to know that information to provide Services or for the purposes outlined in this Policy, and when we no longer need your personal information, we will delete and/or destroy the information as set forth above.

Data Retention

We will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected or as otherwise permitted by law, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, including pursuant to our customary record retention policies.

Information for International Residents

Legal Bases for Processing Your Information

‍In applicable jurisdictions, we rely on the following legal bases for using yourinformation as set out in this Policy, as relevant given the type ofinformation and the context and purpose for using it:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need tocomply with a legal or regulatory obligation; or
• Where we have your consent to process your information in a certain way.‍

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Cross-Border Transfers. Deerfield is based in and operates in the United States and complies with applicable data protection laws in the United States. If you are located outside of the United States, your personal information may be transferred across nation borders and may be accessed by Deerfield vendors and suppliers from countries with varying degrees of protection for your personal information. By agreeing to this Policy, you acknowledge that your data may be transferred to or processed in any jurisdiction, including, without limitation, the United States, in accordance with this Policy and applicable privacy and data protection laws and regulations.

Children’s Data

Our Site and our Services, including our investment management services and other information we make available, are not directed towards children under the age of 16. Deerfield does not knowingly solicit, collect, use, or disclose personal information of any children under the age of 16. By submitting information to Deerfield (whether or not through the Site), you represent and warrant that you are not under the age of 16. If Deerfield learns that any personal information has been submitted by any child under the age of 16, then Deerfield will take the appropriate steps with respect to that information, which may include deletion.

Changes to this Policy

Deerfield reserves the right to change this Policy at any time and without notice. If we make changes to this Policy, we will update the effective date listed at the top of the policy. Any change will be immediately effective upon this date.

Contact Us

If you have any questions or comments about this Policy or if you would like to exercise any of your rights as outlined here, please contact us at 888-532-7488 and ask to speak with a member of our Privacy Team, or send an email to privacy@deerfield.com. Before helping you with your inquiry, we may ask to verify your identity in accordance with applicable law. Residents of the State of California may submit an online request for an accounting of the personal information we maintain about them by completing this online request form.

You may also write to us at:

Attn: Privacy Team
Deerfield Management Company
345 Park Avenue South, 12th Floor
New York, New York 10010