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Privacy Policy

GLOBAL ORPHAN PHARMACEUTICAL, LLC (GOP)

1. GENERAL

2. CONFIDENTIALITY AND SECURITY

3. ADDITIONAL WEB SITE ISSUES

4. POLICY CHANGE

PRIVACY POLICY

Global Orphan Pharmaceutical, LLC (GOP) is recognized as a world class company. We strive to provide our customers, suppliers and partners with exceptional products and services and recognize that building a long-term business relationship with you depends a great deal on trust. This trust begins with our commitment to respecting as well as protecting your privacy and in furtherance of this goal, GOP acknowledges that it respects the privacy rights of its customers, suppliers and partners and shall comply with applicable privacy laws in the countries in which GOP does business.

GOP has structured our web site so that, in general, you can visit GOP on the Web without identifying yourself or revealing any personal information. Once you choose to provide us personally identifiable information (name, address, e-mail address, phone number, etc.) you can be assured that it shall be used to support your relationship with GOP. You can be assured that any such personal information that you submit to GOP shall be protected by industry standard security and management procedures and shall be used only for the purpose for which it was submitted, unless you request or agree otherwise.

This policy does not apply to the practices of companies that GOP does not own or control, or to people that GOP does not employ or manage. GOP provides this Privacy Policy to make you aware of our privacy practices and of the choices you can make about the way your information is collected and used.

1. GENERAL

On GOP’s web site, over the telephone, via email or through the mail, you are able to order products or services from GOP. The types of personal information collected by GOP may include your name, your employer and job title, your contact and billing information for business and home (including telephone number and e-mail address), and your credit card information (if applicable). In order to tailor our subsequent communications to you and continuously improve our products and services, we may also ask you to provide us with information regarding your personal or professional interests, demographics, experience with our products, and contact preferences.

    - GOP collects personal information when you register with GOP, when you use GOP’s products or services. GOP may combine information about you that we have with information we obtain from business partners or other companies.

    - When you register we ask for information such as your name, email address, birth date, gender, zip code, occupation, industry, and personal interests. For some financial products and services we may also ask for your address, Social Security number, and information about your assets. Once you register with GOP and sign in to our services, you are not anonymous to us.

    - GOP collects information about your transactions with us and with some of our business partners, including information about your use of products and services that we offer.

    - GOP uses information for the following general purposes: to customize the advertising and content you see, fulfill your requests for products and services, improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients. GOP uses your information to better understand your needs and provide you with better service. Specifically, we use your information to help you complete transactions requested by you, to communicate back to you, and to offer and update you on GOP services and benefits. Credit card numbers are used only for payment processing and are not retained for other purposes. From time to time, we may also desire to contact you for market research purposes or to provide you with marketing information we think would be of particular interest. You shall not be included in any Directories nor shall GOP reveal your personal information publicly or to any third party (except as stated below), unless we receive your explicit permission to do so. GOP does not sell, rent, or lease your personally identifiable information to others or nonaffiliated companies without your permission. Unless we have your permission, are required by law or under the following circumstances, we shall only share the personal data you provide to us with other GOP entities and/or business partners who are acting on our behalf to help us provide you with our products and services. Such GOP entities and/or business partners are governed by our privacy policies with respect to the use of this data and are bound by this Privacy Policy and applicable confidentiality agreements.

    - We provide the information to trusted partners who work on behalf of or with GOP under confidentiality agreements. These companies may use your personal information to help GOP communicate with you about offers from GOP and our marketing partners. However, these companies do not have any independent right to share this information.

    - We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of GOP’s terms of use, or as otherwise required by law.

    - We transfer information about you if GOP is acquired by or merged with another company. In this event, GOP shall notify you before information about you are transferred and becomes subject to a different privacy policy.

GOP shall not use or share the personally identifiable information provided to us for purposes other than for which the information was originally submitted, without your express permission. We shall also provide you the opportunity to inform us at any time if you choose to opt-out of partial or total contact from GOP and we shall comply with such requests. This choice regarding communications from GOP may be offered on our applications, registration forms or web pages, or at the bottom of on-line or off-line communications from us. If you have any difficulty exercising your choices or if you have any questions or comments regarding our privacy practices, please contact GOP at privacy@gopharmaceutical.com. Your permission shall be secured first, should we ever decide to share your information with third parties that are not acting on our behalf and not governed by our privacy policy.

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2. CONFIDENTIALITY AND SECURITY

GOP is committed to ensuring the security of your information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We use encryption when collecting or transferring sensitive data online such as credit card information. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

Your access to some services and content is password protected. We recommend that you do not divulge your password to anyone. GOP shall never ask you for your password in an unsolicited phone call or in an unsolicited email. You should not disclose your user name and password to others. In addition, if applicable, you should remember to sign out of your GOP account or service at the end of each session. You may also wish to close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place like a library.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, despite our best efforts to protect your personal information, GOP cannot completely ensure or warrant the security of any information you transmit to us, or to or from our online products or services. You transmit all such information at your own risk. However, once we receive your transmission, we make our best effort to ensure its security on our systems.

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3. ADDITIONAL WEB SITE ISSUES

(a) Links to Third Party Web Sites

Links to third party web sites are provided solely as a convenience to you. If you use these links, you shall leave the GOP site. GOP has not comprehensively reviewed all of these third party sites and does not control and is not responsible for any of these sites, their content or their privacy policies. Thus, GOP does not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. Once you link to another site, you are subject to the privacy policy of the new site. If you decide to access any of the third party sites linked to this site, you do this entirely at your own risk.

(b) Cookies Use

A cookie is a piece of text asking permission to be placed on your computer’s hard drive. If you agree, then your browser adds the text in a small file. The general purpose of a cookie is to help a web site owner analyze web traffic on their site or allow an owner to tailor its web application for you based on your individual preferences. GOP’s web site uses only temporary “Session” cookies as part of the customer web navigation experience, tracking unique IDs and information you input for a particular web site session only. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.)

GOP wants to ensure that you understand that accepting a cookie in no way gives us access to your computer or any personal information about you, other than the data you choose to share with us. This practice is strictly enforced. We are aware that a lot of people have concerns about cookies, but we believe that the benefit we both gain from their proper use is worthwhile. We value the relationships we have with our customers, so we respect these concerns. GOP works to continuously improve the web experience and personal data privacy policy and practices.

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4. POLICY CHANGE

If there are updates to the terms of this Privacy Policy, we shall post those changes and update the revision date listed on this document, so you shall always know what information we collect online, how we use it, and what choices you have.

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Date: December 1, 2008