Privacy Policy

Welcome to Ortho Dermatologics

Welcome to www.orthodermatologics.com. This site is owned by Ortho Dermatologics division of Ortho-McNeil-Janssen Pharmaceuticals, Inc. This Privacy Policy is designed to tell you about our practices regarding collection, use, and disclosure of information that you may provide via this site. Please be sure to read this entire Privacy Policy before using or submitting information to this site. This site is intended for use by residents of the United States.

YOUR CONSENT

By using this site, you agree with the terms of this Privacy Policy. Whenever you submit information via this site, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

ABOUT CHILDREN

This site is not intended for children under the age of 13. We will not knowingly collect information from site visitors in this age group. We encourage parents to talk to their children about their use of the Internet and the information they disclose to Web sites.

ACTIVE INFORMATION COLLECTION

Like many Web sites, this site actively collects information from its visitors both by asking you specific questions and by permitting you to communicate directly with us via e-mail, feedback forms, and/or chat rooms. Some of the information that you submit may be personally identifiable information (that is, information that can be uniquely identified with you, such as your full name, address, e-mail address, phone number, and so on).

Some areas of this site may require you to submit information in order for you to benefit from the specified features (such as newsletter subscriptions, tips/pointers, order processing) or to participate in a particular activity (such as sweepstakes or other promotions). You will be informed at each information collection point what information is required and what information is optional.

PASSIVE INFORMATION COLLECTION

As you navigate through a Web site, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection.

We use Internet Protocol (IP) addresses on this site. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, and administer and improve the site.

A "cookie" is a bit of information that a Web site sends to your Web browser that helps the site remember information about you and your preferences.

"Persistent" cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of the Web site visitors find most valuable, and customizing the Web site based on your preferences. This site uses persistent cookies.

"Internet tags" (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the Web site server information such as the IP address and browser type related to the visitor's computer. We do not use "Internet tags" at this site.

"Navigational data" ("log files," "server logs," and "clickstream" data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. This site uses navigational data.

USE AND DISCLOSURE OF INFORMATION

Except as otherwise stated, we may use your information to improve the content of our site, to customize the site to your preferences, to communicate information to you (if you have requested it), for our marketing and research purposes, and for the purposes specified in this Privacy Policy.

If you provide personally identifiable information to this site, we may combine such information with other actively collected information unless we specify otherwise at the point of collection. We will take reasonable measures to prevent personally identifiable information from being combined with passively collected information, unless you consent otherwise.

We may disclose your personally identifiable information to other Johnson & Johnson affiliates worldwide that agree to treat it in accordance with this Privacy Policy. In addition, we may disclose your personally identifiable information to third parties, located in the United States and/or any other country, but only

to contractors we use to support our business (e.g., fulfillment services, technical support, delivery services, and financial institutions), in which case we will required such third parties to agree to treat it in accordance with this Privacy Policy;
in connection with the sale, assignment, or other transfer of the business of this site to which the information relates, in which case we will require any such buyer to agree to treat it in accordance with this Privacy Policy; or
where required by applicable laws, court orders, or government regulations.

ACCESS AND CORRECTION

To keep your personally identifiable information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personally identifiable information in our possession that you have previously submitted via this site.

SECURITY

We take reasonable steps to protect your personally identifiable information as you transmit your information from your computer to our site and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Moreover, where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them.

LINKS TO OTHER WEB SITES

This site may contain links or references to other Web sites. Please be aware that we do not control other Web sites and that, in any case, this Privacy Policy does not apply to those Web sites. We encourage you to read the privacy policy of every Web site you visit.

OTHER TERMS

Your use of this site is subject to our Legal Statement.

HOW TO CONTACT US

If you have any questions, comments, or concerns about this Privacy Policy or the information practices of this site, please contact us as follows:

Ortho Dermatologics
Attn: Information Center
199 Grandview Road
Skillman, NJ 08558-9418

1-877-738-4624

CHANGES TO THIS PRIVACY POLICY

If this Privacy Policy changes, the revised policy will be posted on this site. Please check back periodically, and especially before you provide any personally identifiable information. This Privacy Policy was last updated on January 5, 2009.

SAFE HARBOR PRIVACY POLICY

Ortho Dermatologics a member of the Johnson & Johnson Family of Companies, is 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, Ortho Dermatologics has certified to the Safe Harbor Agreement between the United States and the European Union, with respect to personal data processed as part of our Human Resources Activities. Accordingly, Ortho Dermatologics adheres to the Safe Harbor privacy principles and Frequently Asked Questions, as agreed to by the U.S. Department of Commerce and the European Commission.

SCOPE

This Safe Harbor Privacy Policy sets forth how Ortho Dermatologics handles personal data transferred from countries in the European Economic Area (EEA) to the United States that are collected or received in managing our workforce.

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 Ortho Dermatologics

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 non-public 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 Ortho Dermatologics in conducting human resources activities.

Notice
Ortho Dermatologics will inform individuals about the purposes for which we collect and use personal data about them, how to contact us, the types of non-agent 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
Ortho Dermatologics will offer an individual the opportunity to choose (opt out) whether personal data are (a) shared with a non-agent third party or (b) used for a purpose other than that for which the data were originally collected or subsequently authorized by the individual.
For sensitive personal data, Ortho Dermatologics 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
Ortho Dermatologics 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
Ortho Dermatologics 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, Ortho Dermatologics will take reasonable steps to prevent or stop such processing.

Onward Transfer
Ortho Dermatologics will only transfer personal data to a non-agent 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
Ortho Dermatologics 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, Ortho Dermatologics will take reasonable steps to ensure that the data are accurate, complete, and current.

Information Security
Ortho Dermatologics will take reasonable precautions to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement
Ortho Dermatologics has 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.

LIMITATION ON SCOPE OF PRINCIPLES

Adherence by Ortho Dermatologics to these privacy principles may be limited to the extent required to meet a legal, governmental, national security or public interest obligation.

HOW TO CONTACT US

Please contact us with any questions about the way in which we use personal data. Employees and former employees of Ortho Dermatologics should contact us at:

Chief Compliance Officer, Consumer Sector
Phone: (908) 874-2450
Fax: (908) 874-2477
Consumer_Privacy@its.jnj.com

All other individuals covered by this Policy should contact us at:
Consumer_Privacy@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.

Last Updated: 12-15-2009