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VIVUS BV HCP Locator Privacy Notice

Effective 25 August 2026

This HCP Locator privacy notice (“Privacy Notice”) describes the processing of your personal data specifically in connection with the Healthcare Professional Locator (“HCP Locator”). It explains how VIVUS BV (“we”, “us”, “VIVUS”), as controller, processes your personal data when you use the HCP Locator on our websites or mobile applications from which you linked (“Sites”), when you register for inclusion in the HCP Locator, or when you contact us with requests for information or support in connection with the HCP Locator. It also explains how we use and protect that data and the choices you may make with respect to it.

Please note that the HCP Locator is only available in certain European countries. If the HCP Locator is not available in your country, no data will be processed in connection with this service.

The HCP Locator may contain links to third-party websites/content/services that are not owned or controlled by VIVUS. VIVUS is not responsible for how these properties operate or treat your personal data, so we recommend that you read the privacy policies and terms associated with these third-party properties carefully.

I. Data We Collect and Use from You

You do not have to register as a user to use the HCP Locator to search for healthcare professionals or facilities and we will not identify you unless you contact us via email.

If you are a healthcare professional and wish to be included in the HCP Locator, you will need to register and provide certain professional information so that we can review your registration and, where applicable, publish and maintain your listing.

A. Data Collected from Website Visitors and Users of the HCP Locator

If you use the HCP Locator to search for healthcare professionals or facilities, we process the following data:

  1. Information you provide during use of the HCP Locator

Location information, such as a city or postal code, that you provide when using the HCP Locator to search for healthcare professionals or facilities near you. We will not identify users visiting our website unless you contact us directly per mail or e-mail.

  • Information that may be collected automatically

Certain information may also be collected automatically in connection with your use of the HCP Locator, such as IP address, browser or device information, and technical usage data relating to the map functionality. This may occur where necessary to provide, secure and maintain the HCP Locator and, where applicable, through our third-party map service provider.

B. Data Collected from Healthcare Professionals (HCPs) for inclusion in the HCP Locator

If you are a healthcare professional and register for inclusion in the HCP Locator, we will collect and use the following personal data:

  1. Information you provide during registration

In connection with your registration for inclusion in the HCP Locator on our Sites, VIVUS collects and uses certain personal data that is specific to your registration and inclusion in the HCP Locator. This includes:

  • Professional information that you provide when you register for inclusion in the HCP Locator on our Sites, such as your name, professional title, specialty, clinic or practice name, professional address, professional telephone number, professional email address, website or booking link, professional background, and any other professional practice information you choose to provide for publication;
  • Information used to verify your professional status and eligibility for inclusion in the HCP Locator, such as professional registration, licensure or other verification-related information.
  • Information that may be collected from third-party sources

To verify whether a healthcare professional is eligible to be included in the HCP Locator, we may obtain information from third-party professional data providers, such as VEEVA Systems Inc. (4280 Hacienda Drive Pleasanton, CA 94588, USA), and compare that information with the data submitted during registration. This may include information relating to professional licensure, professional status, specialty, practice details, and other information relevant to verifying eligibility for inclusion in the HCP Locator.

We may also use such information to help ensure that HCP Locator listings are accurate and up to date.

For more information on how VEEVA processes personal data, please refer to VEEVA’s privacy notice at https://www.veeva.com/privacy/.

If you submit any personal data relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

II. How We Use Data

A. Website Visitor and User Data

We may use data collected from website visitors and users of the HCP Locator in the following ways:

  1. To Provide the HCP Locator Service
  2. Provide location-based search functionality, including displaying healthcare professionals or facilities near the city or postal code entered into the HCP Locator;
  3. Transmit location information you enter to the relevant map provider to display search results and map content;
  4. Secure and maintain the HCP Locator;
  5. Prevent misuse of the HCP Locator.
  6. To Comply with the Law/Protect our Rights and Interests

We may also process personal data where necessary to comply with applicable law, regulatory requirements, or to establish, exercise or defend legal claims.

B. Healthcare Professional (HCP) Data

We may use personal data collected from healthcare professionals for inclusion in the HCP Locator in the following ways:

  1. To Provide the HCP Locator Service
  2. Register healthcare professionals for inclusion in the HCP Locator;
  3. Publish healthcare professional profiles in the HCP Locator on our Sites;
  4. Maintain, update, correct or remove HCP Locator listings at your request or as otherwise required.
  5. To Verify Professional Status and Eligibility for Inclusion in the HCP Locator

We may verify whether healthcare professionals applying for inclusion in the HCP Locator meet the relevant eligibility criteria. For this purpose, we may use information provided during registration and information obtained from third-party professional data providers, such as VEEVA.

  • To Comply with the Law/Protect our Rights and Interests

We may also process personal data in connection with the HCP Locator where necessary to comply with applicable law, regulatory requirements, or to establish, exercise or defend legal claims.

III. How We Share Your Personal Data

A. Website Visitor and User Data

We may share personal data processed in connection with your use of the HCP Locator with third-party service providers (“Providers”) who support the operation, hosting, maintenance and administration of the HCP Locator.

If you use the HCP Locator on our website, the location information you enter is transmitted to Google Maps (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to display search results and map content. The map loads automatically when you access the page containing the HCP Locator to provide you with the requested search functionality. In connection with providing such functionality, the providers may also process certain technical information, such as IP address, browser type or device information.

Please note that when cookies are declined, the map will still load automatically, but in this case, we do not track your user interaction. Further information on data processing by Google and your rights can be found in Google’s privacy policy at https://policies.google.com/privacy.

B. Healthcare Professional (HCP) Data

  1. In Connection with the HCP Locator

If you register for inclusion in the HCP Locator on our Sites, the professional information from your HCP Locator profile may be made publicly available on the relevant Site so that users can identify and contact healthcare professionals or facilities.

  • With Providers

We may share personal data processed in connection with the HCP Locator with third-party service providers (“Providers”) who support the operation, hosting, maintenance, verification and administration of the HCP Locator.

IV. Information on Cross Border Transfers of Personal Information Protected under the EU GDPR

When we collect your information in accordance with this Privacy Notice, we may process or share such information outside the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, we will ensure that your personal data is protected at the same level of data protection as within the EEA. Such transfers may occur, in particular, where we use service providers or map functionality providers that process personal data outside the EEA. In such cases, we implement appropriate safeguards, such as Standard Contractual Clauses, and supplementary measures where required. Additionally, we may rely on adequacy decisions of the European Commission, such as the EU-US Data Privacy Framework, for transfers to countries that have been recognized as providing an adequate level of data protection.

You can request a copy of the SCC or other contract ensuring the appropriate level of data protection by contacting us by the contact methods described under “Contact Us”.

V. Legal Grounds for the Collection and Use of your Personal Data

If we ask for your consent to process your personal data, we shall inform you fully as to why we need your consent. This may include, in particular, your consent to the publication of your professional profile in the HCP Locator. Where processing is based on your consent,

We process your personal data on the following grounds:

(1) Use of the search functionality (website visitors/users): to provide the HCP Locator and the services requested by you, including displaying healthcare professionals or facilities near the city or postal code entered by you, and, where applicable, based on our legitimate interest in operating and maintaining the HCP Locator;

(2) Registration and publication of HCP Locator profiles (healthcare professionals): based on your consent; you may withdraw your consent at any time. In that case, we will remove your profile from the HCP Locator, unless we are required or permitted to retain certain information for legal, regulatory or record-keeping purposes.

(3) Verification of professional status (healthcare professionals): based on our legitimate interest in ensuring that only eligible healthcare professionals are included in the HCP Locator;

(4) Responding to requests and maintaining records: based on our legitimate interest and, where applicable, legal and regulatory obligations (cf. II. 3);

(5) Security, integrity and misuse prevention: based on our legitimate interests in ensuring the security, integrity and proper functioning of the HCP Locator and preventing misuse of the HCP Locator.

(6) Use of cookies, similar technologies and external map functionality: based on your consent where required by applicable law, and otherwise on our legitimate interest in providing and maintaining the HCP Locator functionality.

You can object to processing based on our legitimate interest at any time by contacting us as set out below under “Contact Us”.

VI. Cookies and Other Tools

Use of the HCP Locator may involve cookies or similar technologies, in particular in connection with third-party map functionality. Where cookies or similar technologies that are not strictly necessary are used, we will provide you with further information and, where required, obtain your consent through the applicable cookie preference tool https://vivus.com/privacy-policy/

VII. Regular Deletion of Personal Data

HCP Locator profile data will generally be retained for as long as the healthcare professional remains listed in the HCP Locator. If a listing is removed, we will delete or anonymize the profile data unless further retention is required for legal, regulatory or documentation purposes. Records relating to consent, withdrawals, updates or removal requests may be retained for the period necessary to demonstrate compliance with applicable legal obligations.

Website visitor and user data will be retained in accordance with the retention periods set out in the VIVUS global privacy policy.

VIII. Your Rights

The following section explains your rights. The various rights are not absolute, and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under applicable data protection laws.

Subject to the conditions under applicable data protection law, you may have the right to:

  • request access to the personal data stored by us;
  • receive personal data you have provided in a structured, commonly used and machine-readable format where applicable;
  • request rectification of inaccurate personal data;
  • request erasure of your personal data;
  • request restriction of processing;
  • object to processing based on legitimate interests at any time based on ground relating to your particular situation;
  • withdraw consent at any time, where processing is based on consent; and
  • lodge a complaint with a competent data protection authority.

If you wish to lodge a complaint, you may contact the data protection authority responsible for us:

Autoriteit Persoonsgegevens (AP)

IX. Contact Us

The company responsible for collection, use and disclosure of your personal data under this Privacy Notice is VIVUS BV.

If you have any questions about this Privacy Notice, or if you would like to request to exercise any individual rights, please contact us using the contact details provided below:

  • Phone number: 1-888-998-4887
  • E-mail: Privacy@VIVUS.com
  • Mail:
    VIVUS BV
    Strawinskylaan 4117, Office #03-106
    1077 ZX Amsterdam,
    Netherlands

Updates to this Privacy Notice

From time to time, we may update this Privacy Notice. Any changes will be effective when we post the revised Privacy Notice. This Privacy Notice was last updated as of the effective date listed above. If the Privacy Notice changes in a way that significantly affects how we handle personal data, we will take additional steps to inform you of those changes.