Privacy policy
PRIVACY POLICY
Last Updated: October 13, 2024
Secure Pharmaceuticals Inc. (together with its subsidiaries, affiliates, or related companies, the “Company”, “Se-cure Pharmaceuticals Inc”, “our”, “we” or “us”), provides its customers and potential customers ("Customer", “you” or “your”) with our Websites and landing pages including https://femarelle.us/(“Website”), through which we offer and sale products and goods (“Products”) and our associated and ancillary services (collectively “Services”).
This Privacy Policy (“Privacy Policy") forms an integral part of our Terms.
Additional Notice to Specific US States Residents: In the event you are a resident of one of certain US states – please also review Section 12 below ”US Jurisdiction-Specific Notices” to learn more about our privacy practices and your rights under the privacy and data protection legislation which applies in these states.
As we are committed to protecting your rights to privacy, this Privacy Policy further explains how we safeguard your information we collect or to which we may have access, through your use of our Website, the Services or otherwise through marketing campaigns, how such information may be used or shared with others, and how you may exercise your rights related to your Personal Information, as required under applicable laws.
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE ACCESSING AND USING OUR WEBSITE OR SERVICES. BY ACCESSING OR USING OUR WEBSITE OR SERVICES YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES.
POLICY TOPICS
2. Categories of Information Collected and The Purpose of Processing
3. Find Your Femarelle Quiz
4. How we Collect your Information
5. Cookies and Tracking Technologies
6. Sharing Personal Information with third parties, and the categories of such third parties.
7. Data Retention
8. Information Security
9. Where Do We Store Your Information
10. Children
11. Your Rights
12. Jurisdiction Specifications
1. POLICY AMENDMENTS:
We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the Website and the update date will be reflected in the “Last Updated” heading. Subject to applicable law, any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise.
2. CATEGORIES OF INFORMATION COLLECTED AND THE PURPOSE OF PROCESSING:
You are not required to provide us with any Personal Information. However, depending on the Service used, certain features will require processing of Personal Information, or otherwise Sensitive Information.
“Personal Information”: is individually identifiable information, namely information that identifies an individual or may, with reasonable efforts or together with additional information we have access to, enable the identification of an individual, where identification of an individual also includes the association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier, etc.
“Non-Personal Information”: is information that does not personally identify an individual and includes technical information such as the type of device, time stamp, or any Personal Information that has been anonymized or aggregated, provided that such information can no longer be used to identify a specific natural person. For the avoidance of doubt, any Non-Personal Information connected or linked to Personal Information shall be deemed as Personal Information as long as such connection or linkage exists and identifies a natural person. We may also use or disclose to third parties, aggregated, or de-identified information (“De-identified Data”) and we do not limit our third-party providers from using, selling, licensing, distributing, or disclosing de-identified data.
The table below details the types of information we collect, access, share or use, and the purpose for processing such information:
Please note that the actual processing operation per each purpose of use detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction.
In addition, we may use certain Personal Information to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our services and to enforce our terms of use and other policies, as well as to protect the security or integrity of our databases and Website and Services, and to take precautions against legal liability.
To assist you in finding the right Product tailored to your specific symptoms, we offer a quick and easy two-question symptom quiz (“Quiz”). Rest assured; our symptom quiz does not collect any personal information. Your responses are used solely to generate recommendations for Products based on common symptoms and concerns during that specific session, without ascribing any such Quiz data to your personal data and without retaining it once you terminate your session. No personal data will be collected from your interaction with the quiz.
4. HOW WE COLLECT YOUR INFORMATION:
Depending on the nature of your interaction with us and our Website, we may collect Personal Information as follows:
· Automatically – we may use cookies or similar tracking technologies, including through third-parties suppliers (e.g., Google) to gather some information automatically when you interact with our Website.
· Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as where you create an Account, place and order, contact us, provide a proscription, etc.
· From publicly available sources – such as through social media platforms where you open an account through such platforms, credit bureaus when you make a payment (through the use of our payment providers), all to the extent permitted under applicable law.
5. COOKIES AND TRACKING TECHNOLOGIES:
We use “cookies” and similar tracking technologies when you access to, interact with, or use our Website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, enabling automatic activation of certain features (e.g., shopping cart), for statistical purposes (e.g. Google analytics), as well as for advertising purposes. You can find more information about cookies here: www.allaboutcookies.org.
You can learn more about our use of cookies and control your cookies preferences through the use of the designated cookie toolbar on the Website.
6. SHARING PERSONAL INFORMATION WITH THIRD PARTIES, AND THE CATEGORIES OF SUCH THIRD PARTIES:
We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and circumstances:
· Third Party Service Providers: We partner with a number of selected service providers or business associates, whose services and solutions complement, facilitate and enhance our own. These include hosting, data and cyber security services, fraud detection and prevention services, merchant processing, shipping, postal and delivery services, website functionality, manufacturing services, e-mail and text message distribution and monitoring services, advertising, data optimization and marketing services, affiliation and related analytics services, customer support and call center services, as well as our business, legal and financial advisors, and others. Any disclosure or access to Personal Information is strictly subject to such third party’s confidentiality undertakings and the application of appropriate safeguards. These third-party have limited access to your Personal Information solely as needed to perform their services.
· Enforcement: We may disclose Personal Information to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Information to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.
· Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of our Company, of any of our customers, or any members of the general public.
· Our Affiliated Companies: We may share Personal Information internally within our group of affiliated companies for the purposes described in this Privacy Policy. In addition, should we or any of our affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of our assets, your personal information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your personal information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Platform.
7. DATA RETENTION:
Except as specifically detailed above, we retain the Personal Information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until the individual expresses a preference to opt-out.
In certain circumstances, we will retain your Personal Information for longer periods of time and mainly:
· Where we are required to retain Personal Information in accordance with legal, regulatory, tax, or accounting requirements;
· Where we deem retention is necessary to obtain an accurate record of your dealings with us in the event of any complaints or challenges (e.g., adverse event); or
· If we reasonably believe there is a prospect of litigation relating to your Personal Information.
8. INFORMATION SECURITY:
Securing your Personal Information including is of high priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as encryption, access restrictions and permissions, etc.
Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
Please contact us at: Femarelle.us@se-curephara.com, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Information. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Information.
9. WHERE DO WE STORE YOUR INFORMATION:
We maintain Personal Information that we collect from you in secured cloud storage environments provisioned by third party cloud providers that operates globally, including in the United States and Canada. Each such transfer is always conducted in accordance with applicable law. Further, our HQ are in Israel, and your personal data may be shared with our affiliated companies in Israel, always subject to applicable legal obligations.
10. PROTECTING CHILDREN:
In order to access to, interact with or use our Services, you must be over the age of eighteen (18). Therefore, we do not knowingly collect Personal Information from minors under the age of eighteen (18) and do not wish to do so. If we learn that we have collected personal information from a child under eighteen (18) years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at femarelle.us@se-curepharma.com.
11. YOUR RIGHTS:
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your Personal Information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
In the table below, you can review how Consumers can exercise their rights, and appeal such decision, or if and when we sell or share the personal data, and how to opt-out.
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RIGHT TO KNOW (ACCESS) |
You have the right to confirm whether we collect Personal Information, or Personal Data, and to know the information specifically collected on you. |
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RIGHT TO CORRECTION |
You have the right to correct inaccuracies in your Personal Information, or Personal Data, taking into account the nature of the processing and the purposes. |
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RIGHT TO DELETION |
You have the right to delete the Personal Data, or Personal Information we collected from the you. You do not need to create an account with us to submit a request to know or delete. The deletion right is not absolute and in certain circumstances we may deny such request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) Debug products to identify and repair errors that impair existing intended functionality; (4) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) Comply with the law or legal obligation; (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) Make other internal and lawful uses of that information that are compatible with the context in which you provided it. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action. |
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RIGHT TO PORTABILITY |
You have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. |
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RIGHT TO OPT OUT FROM: (I) SELLING PERSONAL DATA; (II) RIGHT TO OPT OUT FROM TARGETED ADVERTISING; AND (III) RIGHT TO OPT OUT FROM PROFILING |
You have the right to opt out of the sale of your Personal Data, or Personal Information, for the purposes of targeted advertising, sale to a third party for monetary gain, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or any other consumer. You may authorize another person acting on your behalf to opt out (including by technical tools and opt out signals). We do not profile you in a manner that has significant effect of you or and other consumer, therefore there isn’t an opt-out option. We do not “sell” or “share” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information or Personal Data in direct exchange for money or some other form of payment, however, we do share Personal Information or Data for analytic and marketing purposes, including targeted advertising, when we promote our Website or products. In most cases we obtain Personal Data, or Personal Information collected automatically from our Website and your actions therein, and do not combine it with your actions on other websites or apps, however, our third-party partners might do so, when providing analytic or advertising services to us. You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising”, or “targeted advertising”, often referred to as “interest-based advertising” as well. You may opt out through the “do not sell or share my personal information” button or the cookie toolbar available within the Websites’ footer. You may further opt out through device settings by using Self-Regulatory Program for Online Behavioral Advertising such as: · Digital Advertising Alliance’s (“DAA”): https://www.aboutads.info/choices · Network Advertising Initiative (“NAI”): https://www.networkadvertising.org/choices. Last, you are able to install privacy-controls in the browser's settings to automatically signal the opt-out preference to all websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control as a valid request to opt-out of the sharing of information linked to your browser. If you opt-out, you will still see ads online, but these ads will not be based on your inferred interests. Some automated means may still be used to collect information about your interactions with our online services for the other purposes such as to remember user preferences or enable specific functionality. We use necessary cookies to make our Website’s work. Necessary cookies enable core functionality such as security, network management, and accessibility. You cannot disable those. You can read more about targeted adverting and take additional steps to control targeted advertising from many ad networks and exchanges by visiting the Digital Advertising Alliance (www.optout.aboutads.info). As online environments continue to evolve, additional opt-out mechanisms or privacy settings may become available to you. We encourage you to review the information on opt-outs and settings that browser owners, device manufacturers, technology companies, and industry associations make available to you. You can opt-out from receiving our marketing emails by clicking “unsubscribe” link. |
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RIGHT TO APPEAL |
If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. |
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NON-DISCRIMINATION |
Such discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. We do not discriminate our users. |
12. JURISDICTION SPECIFICATIONS
General Applicability and Jurisdictions
This section 12 applies to residents of specific US States under applicable specific state laws, including residents of Virginia, Connecticut, Colorado, Utah, Texas, Oregon, Montana (effective of October 1, 2024), and effective of January 1, 2025 – Nebraska, New Hampshire, New Jersey, Delaware, and Iowa, as amended or superseded from time to time and including any implementing regulations and amendments thereto (collectively, “US Privacy Laws”). Any term not defined herein under this section 12 shall have the meaning ascribed to such term in the Privacy Policy above or applicable US Privacy Laws.
The specific disclosures in this Section 12 supplements our general Privacy Policy as detailed above and provides additional details to the extent we are deemed as a “Business” or “Controller” under applicable US Privacy Laws -- for example where we process Visitor’s information regarding their use of the Website or as Customers purchasing our products through the Website.
The Personal Information We Process
Section 2 “CATEGORIES OF INFORMATION COLLECTED AND THE PURPOSE OF PROCESSING”, describes the categories of Personal Data that are collected and processed, and the purposes for which such Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for a materially different, unrelated, or incompatible purpose without obtaining your consent. As further set forth above, collected Personal Data may include, depending on your interaction with us:
· Contact Communications Information – including your identifiers and contact information (name, email, phone, etc.), the content of your inquiry, and additional information as provided voluntarily by you, such as your workplace and position, country of residence, etc. – collected and processed to respond to your inquiry and to keep a record of our interaction with you.
· Checkout and Account Registration - When placing an order for Products on the Websites, you may decide to create an account or continue as a guest. During the transaction, we process your transaction data including your identifying and contact info, purchased goods, transaction summary, shipping and delivery data, etc. We process such data for providing you with your purchased Products.
· Payment Information - When you purchase a Product through the Website we will process your payments by third party vendors. We do not collect your payment information, we may however, keep the last credentials of your credit card in case of recurring payments.
· Usage Data - We perform such automatic collection through use of cookies, web beacons, unique identifiers, and similar technologies which allow us to collect information about the pages and screens you view, the links you click, and other actions you take when using our Website, to keep track on your actions as well as remember your preferences, etc..
· Online Identifiers and Advertising and Targeting data – your IP address, location and time zone setting, operating system and platform, browser plug-in types, domain name and your choice of browser, approximate location (derives from IP address), etc. – processed as part of our technical website management and operation, analytics and online marketing activity.
· Analytics Data – we may process certain information on an aggregated, statistical and de-identified manner for measuring the usage of our Services. We do so to allow ourself improve and further develop our Services.
· Newsletter Registration Information – such as your email, phone number, and your interaction with the messages and content we will send you – collected and processed for sending you news, promotional material and updates regarding our services per your consent and subject to applicable law.
· Review and Feedback Data - Where you submit a review or survey regarding your satisfaction with our Products and Services, you may share information such as rating, free text and an image you actively share when submitting such review.
Please note that under US Privacy Laws, Personal Data does not include publicly available information and information that cannot be reasonably linked to you, directly or indirectly, such as de-identified or aggregated data, and information governed by other state or federal laws, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA), Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, National Security Exchange Act of 1934, higher education data and employment data, etc.
“Sensitive Data” under US Privacy Laws is generally defined as data revealing racial or ethnic origin, religious beliefs, mental or physical health history, condition or diagnosis, sex life or sexual orientation, citizenship or immigration status, genetic or biometric data that can be processed/is processed to uniquely identify an individual, precise geolocation or personal data from a known child. As a “Business” or “Controller” (i.e. the legal owner of personal data), we do not collect or process or use any of your Sensitive Data. Our Quiz may include certain information which may have been deemed sensitive, however, as explained above, we do not process such data in an identified manner.
Disclosures of your Personal Data to Third Parties, and Sale or Share of Personal Data
Under Section 6 of our Privacy Policy, “SHARING PERSONAL INFORMATION WITH THIRD PARTIES, AND THE CATEGORIES OF SUCH THIRD PARTIES”, you will find details regarding the categories of third parties we share Personal Data with for business purposes.
We do not sell your personal information for profit. However, we do engage in targeted advertising on the website. Some of those marketing activities, when conducted through the use of third parties, may be considered a “Sale” or “Share” under certain US Privacy Laws. In this context, as is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third-party businesses to collect information directly from your browser or device through cookies or similar tracking technology when you visit or interact with the website, for example, for collection of Online Identifiers and Advertising and Targeting data as detailed above. These third parties use this personal information to deliver targeted advertising (also known as “cross-context behavioral advertising”) and personalized content to you on our website, on other sites and services you may use, and across other devices you may use, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. To learn more about this please read section 5 of the Privacy Policy regarding Cookies. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the processing of personal information for purposes of targeted advertising through the use of the Cookie Toolbar on the website’s footer or as described above in Section 11 of the Privacy Policy.
We do not knowingly sell or share personal information of individuals younger than 16 years of age. Similarly, as a “Business” or “Controller”, we do not collect or process, therefore not Sell or Share, any Sensitive Data.
Exercising Your Privacy Rights
Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the rights detailed in Section 11 of the Privacy Policy, “Your Rights”, through filling out our DSR form and sending it to us by email at: Femarelle.us@se-curepharma.com. We reserve the right to ask for reasonable evidence to verify your identity before providing you with any such information per applicable law, including requesting a photo ID or other similar documentation and records. We will always maintain the privacy and security of such evidence.
Further, and as explained in Section 11 above, certain rights can be easily executed independently by you without the need to contact us, for example: (i) You can opt-out from receiving our marketing emails by clicking the “unsubscribe” link; (ii) You can use the cookie settings tool on our Website to change your preferences; (iii) you can use certain third party technologies and interfaces, including through your browser settings or mechanisms such as the DAA or NAI.
Authorized Agents
In certain circumstances, and subject to applicable US Privacy Laws, you may permit an authorized agent to submit requests on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf or provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney. For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent with permission to submit the request, and it may take additional time to fulfil agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the individual on whose behalf the request was made.
Appeal Rights
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request, by contacting us as instructed in our response. Please send your appeal request with a summary of the request and decision you want to appeal to Femarelle.us@se-curepharma.com.
Not more than 60 days after receipt of an appeal, and always in accordance with the timelines set by the applicable US Privacy Laws, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason for the decision.
If you are not happy with our response, depending on your jurisdiction, you may have the right to lodge a complaint against us with the relevant State’s Attorney General:
· Colorado Attorney General as follows: Colorado AG at https://coag.gov/file-complaint .
· Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint / or by phone (860) 808-5318.
· Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform .
· Utah Attorney General at https://www.attorneygeneral.utah.gov/contact/complaint-form/.
· Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.
· Oregon Attorney General at https://www.doj.state.or.us/consumer-protection/contact-us/.
· Montana Attorney General at https://dojmt.gov/consumer/consumer-complaints/.
· Nebraska Attorney General https://ago.nebraska.gov/constituent-complaint-form.
· New Jersey Attorney General at https://www.njoag.gov/contact/file-a-complaint/.
· New Hampshire Attorney General at https://onlineforms.nh.gov/app/#/formversion/e0c5d644-c9d8-4056-a7cc-24d29c446fcb.
· Delaware Attorney General at https://attorneygeneral.delaware.gov/fraud/cmu/complaint/.
· Iowa Attorney General at https://www.iowaattorneygeneral.gov/for-consumers/file-a-consumer-complaint.
Notice to Nevada Residents
Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to Femarelle-us@se-curepharma.com.
13. GENERAL INFORMATION
This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court situated in Israel.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Information, you may contact our privacy team at femarelle.us@se-curepharma.com
