PRIVACY/CONSENT GUIDELINES FOR CONSUMER MATERIALS
( With the issuance of these guidelines, the online consent section of the Guidelines for Pfizer Websites will be replaced with a cross-reference to this document.)

These guidelines apply to the collection by Pfizer Pharmaceuticals Limited marketing teams of consumers' personal information by any channel, including hard copy or online forms, business reply cards or telephone. Materials covered include, but are not limited to, disease management program enrollment forms, rebate offers, sweepstakes offers, literature requests, loyalty programs, screenings, internet programs. The guidelines apply only when the consumer is to provide personally identifiable information, such as name and address or email address.

The guidelines are to be followed by all product Review Committees and communicated to and followed by any vendors preparing these types of materials on behalf of Pfizer.

1. In cases where the consumer's personal information is collected in connection with the consumer's request for information or for participation in a Pfizer program, there may be two categories of information to be collected:

(a) the information needed to fulfill the consumer's current request for information or to participate in a particular program - often name and address only will be needed for this purpose; and

(b) additional information, such as gender, ethnicity, birth date, phone number or other demographic or health-related information, not needed to fulfill the consumer's request, but which is important for marketing purposes.

The forms used to collect this information must carefully separate out these two types of information and must clearly and conspicuously designate all category (b) information as OPTIONAL.

2. All forms used must include the following privacy statement or link to this statement:
"Pfizer respects your right to have personal and medical information kept confidential. Pfizer Inc. and companies working with Pfizer will use the information you provide to [insert here the appropriate consumer-directed choice as indicated by completion of the form, for example "fulfill your request", "provide you with the information you are requesting", "enroll you in this program" "process your rebate request", other relevant purpose]. It will not be shared with any third parties (such as outside mailing lists).

3. Obtaining Broad Consent: In order to use any consumer information for any reason beyond the fulfillment of the consumer's current request or to obtain permission to contact a consumer in the future, a consent ("opt-in") with the following wording must be obtained from the consumer. It should be provided immediately following the statement in 2. above:

"When you sign below, you also agree that Pfizer and companies working with Pfizer may:
    
กค Use your information to help develop new Pfizer products, services, and programs you may find useful
    
กค In the future, provide you with materials you may find useful
    
กค Contact you about health-related topics

*Signature:_____________________

Or, when you check this box, you indicate that you want us to use the information you are now providing only to ["send you the information on" or "enroll you in", etc.] [specify only the product/program covered by the consumer's current request].

Please note that if the consumer either: (i) fails to indicate agreement with the broad consent (i.e., has not opted-in) or (ii) does select the second statement (limiting the permission), then the additional uses and further contact are not authorized.

Also, note that wording used in the second statement is not intended and should not be used as opt-out language for subsequent communications; it only limits consent for this transaction. See section 4 below for specific opt-out guidelines.

*[For online forms only, instead of the signature line, the form will simply indicate that "by clicking here and submitting this form you agree to the above" (i.e., no signature line are needed for online forms). For interactive voice recorded interactions, the script will include the statement above and will provide a way for the consumer to affirmatively indicate agreement with the statement.]

4. In all follow-up interactions related to a specific program, a simple mechanism to "opt-out" of that specific program must be provided. This opt-out does not extend to other Pfizer programs nor does it apply to the existence of the data within Pfizer's databases. The following wording is to be used for any opt-outs:

"By [checking this box, submitting this email, calling this toll-free number or other simple action], you indicate to us that you no longer wish to ["participate in" or "receive information about"] [specific program or product]."

5. All materials must be reviewed and approved by the Review Committee for the relevant marketing team consistent with these guidelines.

 
 
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