Consumer Health Data Privacy Policy

CONSUMER HEALTH DATA PRIVACY POLICY

Last Updated: January 7, 2025

Milestone Pharmaceuticals USA, Inc., along with our subsidiaries and affiliates, (collectively, “Milestone,” “we,” “us,” and “our”) are committed to protecting the privacy and security of your personal information. This Consumer Health Data Privacy Policy (“Policy”) supplements the Milestone Privacy Policy and applies to personal information defined as “Consumer Health Data” subject to the Washington State My Health My Data Act.

  1. What categories of Consumer Health Data do we collect?
  2. From what sources do we collect Consumer Health Data?
  3. For what purposes do we collect and use Consumer Health Data?
  4. To what third parties do we disclose Consumer Health Data?
  5. What are your rights with respect to your Consumer Health Data?
  6. How will you know about updates to this Policy?
  7. How can you contact us?

1. What categories of Consumer Health Data do we collect?

The Consumer Health Data we collect depends on the context of your interaction with us. Examples of Consumer Health Data we collect include information about an individual’s:

  • health conditions, treatment, diseases, or diagnoses;
  • social, psychological, behavioral, and medical interventions;
  • use or purchase of medications or prescribed medications;
  • diagnoses or diagnostic testing, treatment, or medication;
  • health-related surgeries or procedures;
  • measurements of health information;
  • symptoms of use or adverse events; and
  • information that could identify an attempt to seek health care services or information.

2. From what sources do we collect Consumer Health Data?

We collect Consumer Health Data from the following sources:

  • Directly from you when you interact with us or our service providers or use our products, services, or programs;
  • Indirectly from you when you visit our websites through use of cookies and other tracking technologies;
  • From healthcare providers, pharmacies, insurers, and funding partners; and
  • From publicly available sources such as social media websites and public databases.

3. For what purposes do we collect and use Consumer Health Data?

We use the categories of Consumer Health Data listed in Section 1 for the following purposes:

  • Respond to your questions and communicate with customers and prospective customers
  • Operate, manage, and maintain our business and maintain records
  • Provide, develop, improve, and maintain our products and Services
  • Analyze and better understand consumers’ needs, preferences, and interests and conduct internal business analysis and research
  • Advertise and promote our products and services, including by contacting you regarding products, services, and topics that may be of interest to you
  • Engage with current and prospective advertisers, advocacy organizations, service providers, and third parties
  • Undertake quality and safety assurance measures and conduct risk and security controls and monitoring
  • Detect and prevent fraud and perform identity verification
  • Perform accounting, audit, and other internal functions, such as internal investigations
  • Comply with law, legal process, and internal policies
  • Exercise and defend legal claims
  • For any other purpose you may agree to at or before the time the Consumer Health Data is collected

4. To what third parties do we disclose Consumer Health Data?

In addition to sharing with service providers, we share the categories of Consumer Health Data listed in Section 1 with the following third parties:

  • Affiliates including Milestone Pharmaceuticals, Inc.
  • Certain third parties with your consent or direction. These parties may include health care providers, pharmacies, or insurers.
  • Other third parties to protect our rights, defend or pursue a legal claim, or investigate or prosecute illegal activities.
  • Government or judicial authorities or agencies to comply with a subpoena, court order, governmental inquiry, legal process, legal obligation, or to protect the rights, property, or safety of other users or the public. This includes complying with adverse event reporting obligations.

We may also share Consumer Health Data with a successor entity or purchaser upon a merger, consolidation, or other corporate reorganization in which we participate, or pursuant to a financing arrangement.

5. What are your rights with respect to your Consumer Health Data?

Washington residents have the following rights with respect to their Consumer Health Data, subject to certain exceptions:

  • The right to confirm whether we process your Consumer Health Data, and to access and receive a copy of your Consumer Health Data;
  • The right to a list of all third parties and affiliates with whom we have shared or sold your Consumer Health Data and an email address or other online mechanism that you can use to contact each third party;
  • The right to delete your Consumer Health Data; and
  • The right to withdraw consent to the collection, sharing, or selling of Consumer Health Data.

You can submit a request to exercise these rights using any of the mechanisms listed in Section 7 below. Depending on the type of request, we may need to verify your request before we can fulfill it. Please note that certain exceptions may apply to these rights (e.g., we may be unable to honor a request to delete if it conflicts with our legal obligation to retain and report adverse event data). Finally, please review the Milestone Privacy Policy for additional rights and choices you may have with respect to your personal information more generally.

You also have the right to appeal any decisions we make in response to your rights request. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

6. How will you know about updates to this Policy?

This Policy is subject to change at our discretion, which will be indicated by updating the “Last Updated” date at the top of the Policy.

7. How can you contact us?

If you have questions about anything contained in this Consumer Health Data Privacy Policy, or if you would like to exercise your privacy rights, please contact us at:

Milestone Pharmaceuticals, Inc.
1111 Dr. Frederik-Philips Blvd, Suite 420
Montreal, (Quebec), H4M 2X6 Canada
privacy@milestonepharma.com