CMP Pharma Consumer Health Data Privacy Policy
Nov 2026
1. What this policy covers
This Consumer Health Data Privacy Policy explains how CMP Pharma, Inc. (“CMP,” “we,” “us”) collects, uses and shares consumer health data through www.cmppharma.com, our product websites, our co-pay savings pages and our Living With Dysphagia page (together, the “Sites”). It supplements, and does not replace, our Privacy Policy and applies to residents of Washington, Nevada and Connecticut and to anyone whose consumer health data is collected in those states.
“Consumer health data” means personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health status. On our Sites this includes information you enter into a co-pay savings or patient-support form, and inferences about your health interests that could be drawn from your visits to pages about a medical condition or a prescription product.
This policy does not cover protected health information governed by HIPAA, de-identified data, or information we hold about healthcare providers in their professional capacity.
2. Consumer health data we collect and why
We collect only the consumer health data listed below, and only for the purposes listed. We do not collect, use or share consumer health data for any other purpose without first asking for your consent.
| Category | Examples | Purpose |
|---|---|---|
| Co-pay savings enrollment data | Name, date of birth, contact details, the CMP product prescribed, insurance type, pharmacy and prescriber information [confirm fields with co-pay vendor] | To enroll you in, administer and verify eligibility for the co-pay savings program; to detect fraud; to meet program and legal reporting requirements |
| Information you send us | Health or treatment details you include in a message, medical-information request, adverse-event report or product complaint | To respond to you and to meet FDA and other safety and regulatory reporting obligations |
| Health inferences from Site use | Pages viewed (for example, a condition page or product page), time on page, clicks, referral source, IP address and device identifiers, where these could reveal a health interest | To operate, secure and improve the Sites; to measure how content is used; and, only with your opt-in through the cookie banner, for analytics and marketing |
We do not use session-replay or advertising tools on pages that discuss medical conditions or our co-pay program, and we do not use biometric data, precise geolocation or geofencing in connection with health care facilities.
3. Where the data comes from
- You, when you complete a co-pay savings form, contact us, or report a side effect or product complaint.
- Your device and browser, through cookies, pixels and similar technologies, as described in our Privacy Policy and controlled through our cookie banner. Non-necessary cookies load only after you choose “Accept All.”
- Our co-pay program administrator, which may confirm your enrollment, claims and eligibility to us [confirm with vendor contract].
- Pharmacies, prescribers and insurers, only to the extent needed to process a co-pay claim you submitted.
We do not buy consumer health data from data brokers and we do not combine Site browsing data with co-pay enrollment data to build health profiles.
4. How we sell consumer health data
We do not sell consumer health data, and we will not do so without your separate, signed authorization. We share it only as follows:
| Who we share with | What | Why |
|---|---|---|
| Co-pay program administrator and claims processors | Co-pay enrollment and claims data | To run the program on our behalf under contracts that limit use to our instructions |
| Website hosting, security and analytics providers | Technical and Site-interaction data that may reveal a health interest | To host, secure and measure the Sites; analytics only with your opt-in |
| CMP affiliates | Any category above | For the purposes in Section 2 |
| Regulators and safety-reporting bodies (for example, FDA) | Adverse-event and product-complaint information | To meet legal reporting duties |
| Legal, compliance and professional advisors | As needed for the matter | To obtain advice, respond to lawful requests and protect legal rights |
We do not share consumer health data with third-party advertisers. Where our general Privacy Policy allows disclosure to advertising partners, that disclosure excludes consumer health data.
5. Your rights and how to exercise them
You have the right to:
- Confirm whether we collect, share or sell your consumer health data and access it.
- Receive a list of the third parties and affiliates with which we have shared or sold it, with their email address or other online contact.
- Withdraw consent to our collection or sharing of your consumer health data.
- Delete your consumer health data, including from our systems, backups and the service providers we share it with.
To make a request, email compliance@cmppharma.com or call 1-800-227-6637. We will confirm your request and respond within 45 days; we may extend once by 45 days and will tell you if so. We may ask for information to verify your identity. An authorized agent may act for you if they can show your authorization.
If we deny your request, you may appeal by emailing compliance@cmppharma.com with “Consumer Health Data Appeal” in the subject line. We will respond within 45 days. If your appeal is denied, you may contact your state Attorney General. In Washington, this can be done at www.atg.wa.gov, in Nevada at ag.nv.gov, and in Connecticut at portal.ct.gov/ag.
We will not discriminate against you for exercising these rights.
6. Changes and contact
Effective date: November 2026. If we change how we collect or share consumer health data, we will update this policy and, where the law requires, ask for your consent before applying the change to data we already hold.
CMP Pharma, Inc., 8026 East Marlboro Road, Farmville, North Carolina 27828 · compliance@cmppharma.com · 1-800-227-6637