Information We Collect
When you agree to participate in one of our surveys, we collect the following categories and specific pieces of personal information from the following sources:
|Categories of Personal Information Collected||Specific Personal Information||Source of Personal Information|
|Identifiers||Your name (including any nickname or alias you have used), postal address, Internet Protocol address, e-mail address, Social Security number, or other similar identifiers||Information available on the internet, including social media sites such as LinkedIn, and information you provide to us in connection with your decision to participate in a survey|
Use and Disclosure of Information
Deerfield may use the personal information we collect about you for the following purposes:
- To contact you or otherwise provide you with information or to uphold our responsibilities under our survey participant agreement with you.
- For internal business purposes, such as auditing, data analytics and research to create, develop, operate, deliver and improve our investment management services, and investor and survey participant communications.
We may share your personal information in a limited number of circumstances, including: (i) to third parties with whom Deerfield works to enhance investment management services that Deerfield provides; (ii) to respond to a subpoena or court order, judicial process or regulatory inquiry; (iii) to protect or defend against fraud, lawsuits, claims or other liabilities; (iv) to protect the security of our systems, or to protect our rights or property; (v) in connection with a proposed or actual sale, merger, or transfer of all or a portion of Deerfield’s business; and (vi) to otherwise assist Deerfield in offering investment management services.
Your Choices & Rights
Based upon where you reside, certain choices and rights with regards to your personal information may be available to you. Please see below for information on how to contact us to exercise these rights.
Under the General Data Protection Regulation (“GDPR”), residents of the European Economic Area (“EEA”) have the following rights:
- The right to object to our processing of your personal information.
- The right to request that your personal information be erased or restricted from further use.
- The right to request a copy of the personal information we hold about you.
- The right to correct, amend, or update personal information you have given us.
- The right to context any automated decisions we made about you.
When handling a data access or correction request, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. Such requests are provided free of charge, however, a reasonable fee may be applied to cover our administrative costs incurred for requests that are manifestly unfounded, excessive, or repetitive.
Under the California Consumer Privacy Act of 2018, as amended (“CCPA”), residents of the State of California are provided with specific rights regarding the collection and storage of their personal information.
Beginning on January 1, 2021, you have the right to request that we provide to you the following information about our collection and use of your personal information over the past twelve (12) months. Once your verifiable consumer request has been confirmed, we will disclose to you:
- The categories of personal information have collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share or have shared that personal information.
- The specific pieces of personal information we have collected about you (also called a data portability request).
- If we have not sold or disclosed your personal information for a business purpose, we will disclose this fact. If we have sold or disclosed your personal information for a business purpose, including direct marketing, we will provide you with a list of disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Under the CCPA, you have the right to know whether your personal information is being sold. Deerfield does not sell your personal information.
CCPA Deletion Request Rights (as of January 1, 2021)
You have the right to request that we delete any of the personal information collected from you and retained, subject to certain exceptions. Once your verifiable consumer request is confirmed, we will delete and direct our service providers to delete your personal information from our records. Your request to delete the personal information collected may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA.
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. We restrict access to your personal information (if any) to those employees who need to know that information to provide investment management services to you and when we no longer need your personal information, we will delete and/or destroy the information per our data destruction policies.
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 expressly consent to the processing of your data in any jurisdiction, including, without limitation, the United States of America, in accordance with this Policy and applicable privacy and data protection laws and regulations, including Standard Contractual Clauses approved by the European Commission; EU-US Privacy Shield; Binding Corporate Rules; and Binding Corporate Processor Rules.
Changes to this Policy
Deerfield reserves the right to change this Policy at any time and without notice. Where the change is material, we will provide notice to you as required by data protection laws.
Our surveys and investment management services are not directed towards children under the age of 13. Deerfield does not knowingly solicit, collect, use or disclose personal information by any children under the age of 13. By submitting information to Deerfield, you represent and warrant that you are not under the age of 13. If Deerfield learns that any personal information has been submitted by any child under the age of 13, then Deerfield will take the appropriate steps to delete this information.
Questions about this Policy & How to Exercise Your Rights
If you have any questions or comments about this Policy or you would like to exercise any of your rights as outline here, please contact us at 888-532-7488 and ask to speak with a member of our Privacy Team or send an email to [email protected]. 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:
Deerfield Management Company
345 Park Avenue South, 12th Floor
New York, New York 10010
If, as an EEA resident, you believe that we have not adequately resolved any such issues, you have the right to contact your EU supervisory authority.
Last Updated: January 2021