Global Cross Border Privacy Policy

Review date : 1 February 2021
Effective date : 1 June 2021

At Organon, our mission to deliver ingenious health solutions that enable people to live their best lives extends to respecting the privacy of individuals and protecting personal information.

We strive to conduct our business in accordance with our privacy principles because we believe they demonstrate our unwavering commitment to ethical and responsible data processing practices. We recognize that innovation and new technology drive continual change and so we aim to promptly adapt how we apply our privacy principles in response to those changes.

This Policy defines our global standards for management and protection of Personal Information as it moves across country borders by or on behalf of our Company, regardless of the country from which it originates or to which the Personal Information may be transferred. It describes our core commitments supporting compliance with our APEC Cross-Border Privacy Rules certification. It applies to our operations in every country, including the data transfers necessary to carry out those activities. This Policy also applies to all people about whom we process information, including, but not limited to, health care professionals and other customers; prospective, current and former employees and their dependents; patients; caregivers; researchers and research study participants; scientific and ethics committee members; business partners; investors and shareholders; government officials; and other stakeholders.

All Company Employees and Senior Leaders have core privacy responsibilities they must uphold.

We recognize that inadvertent errors and misjudgments related to protection of information about people can create potential privacy risks for individuals, and reputational, operational, financial, and compliance risks for our Company. We provide appropriate training on this Policy to employees and other personnel who have permanent or regular access to Personal Information, are involved in the collection of data, or help in the development of tools used to process Personal Information. Every employee of our Company, and others who process information about people for our Company, is accountable for understanding and upholding their obligations under this Policy and applicable Laws.

Our Privacy Values and Standards

We uphold our privacy values in everything we do. Our four privacy values are:

Respect

Trust

Prevent Harm

Compliance

We recognize that privacy beliefs often relate to the essence of who we are, how we view the world and how we define ourselves, so we strive to respect the perspectives and interests of individuals and communities, and to be fair and transparent in how we use and share information about them.
We know that trust is vital to our success, so we strive to build and preserve the trust of our customers, employees, study subjects, and other stakeholders in how we respect privacy and protect information about people.
We understand that misuse of information about people can create both tangible and intangible harm to individuals, so we seek to prevent risk to physical safety, financial, reputational and other types of privacy harm to individuals.We have learned that laws and regulations cannot always keep pace with the rapid change in technologies, data flows, and associated shifts in privacy risks and expectations, so we strive to comply with both the spirit and letter of privacy and data protection laws and regulations in a manner that drives consistency and operating efficiency for our global business operations.
  1. We embed our privacy standards into activities, processes, technologies and relationships with third parties that use Personal Information. We design privacy controls into our processes and technologies that are consistent with our privacy values and standards and applicable law. Our eight (8) privacy principles set forth below summarize our privacy standards and core requirements for processes, activities and their supporting technologies at a high level.

    Privacy Principle

    Our Core Commitments

    1. Necessity – Prior to collecting, using, or sharing Personal Information, we define and document the specific, legitimate business purposes for which it is needed.

    • We determine what Personal Information is needed, and for how long, for defined business purposes and applicable legal requirements. We document our determination.
    • We do not collect, use or share more Personal Information than is needed or retain it in identifiable form for longer than is needed for those defined business purposes and applicable legal requirements.
    • We anonymize or deidentify the Personal Information when business needs require that data about an activity or process involving Personal Information is retained for a longer period of time.
    • We ensure that these necessity requirements are designed into any supporting technology and that they are communicated to third parties supporting the activity or process.

    2. Fairness – We process Personal Information in ways that are fair to the people to whom those data relate.

    • We determine whether the proposed collection, use or other processing of Personal Information presents a reasonably likely or severe risk of tangible or intangible harm to individuals in accordance with our privacy value to Prevent Harm.
    • If the nature of the data, types of people, or the activity present a reasonably likely and/or severe risk of tangible or intangible harm to individuals, we ensure that the risk of harm is outweighed by a corresponding benefit to those individuals or to our mission of saving and improving lives, and mitigated by the measures, safeguards and mechanisms we have put in place.
    • Where the risk appears to outweigh the benefits to individuals, we apply the most relevant security and protection measures, inform individuals of this fact, and seek the advice of competent regulatory authority, as required.
    • We only process Sensitive Information with the explicit consent of individuals, as expressly required or expressly permitted by applicable law.
    • Where the risk appears to outweigh the benefits to individuals, we document the risk analysis, and implement safeguards to minimize risks as much as possible.

    3. Transparency – We process Personal Information in ways or for purposes that are readily transparent to the people to whom the data relate.

    • All individuals about whom Personal Information is processed under this Policy shall have a right to a copy of this Policy. We will make copies of this Policy available online at www.organon.com/privacy, and provide electronic and/or paper copies of this Policy upon request made to the addresses listed below.
    • When Personal Information is collected directly from individuals, we inform them, prior to collecting the information and through a clear, conspicuous, and easily accessible privacy notice or similar means, of (1) the company entity or entities responsible for the processing; (2) the contact details of our Chief Privacy Officer and/or the regional/local Data Privacy Officer; (3) what information will be collected; (4) the purposes for which it will be used; (5) the legal basis for our processing of the data; (6) with whom it will be shared, including any requirements to disclose Personal Information in response to lawful requests by government authorities; (7) whether and how we will transfer the Personal Information to other countries, including identifying the relevant countries where feasible; (8) how long the data will be retained or the criteria by which we make that determination; (9) how the individuals can ask a question, raise a concern or exercise their rights related to their Personal Information; (10) how they can withdraw any consent they have provided; (11) their right to lodge a complaint with a supervisory authority; (12) any obligation to provide Personal Information and the consequences of not doing so; (13) any automated decision-making, including profiling, that may be done; and (14) a link to this Policy, where possible and appropriate. Our comprehensive privacy notices for many of our stakeholders are available online at https://www.organon.com/privacy/contact/
    • When Personal Information is obtained through observation, sensors, or other indirect means, it may not be possible to provide a privacy notice directly to the individual at the time the information is collected. In such cases, we assure transparency to the individual through other means, such as posted or printed on the device or materials associated with the device that will obtain the information.
    • When Personal Information is collected by way of a web site, mobile app, or other online application or resource, we apply the technology specific standards set forth in our Internet Privacy Policy and our Global Online Tracking Policy to ensure the requirements for being transparent in accordance with this Policy have been met.
    • When Personal Information is collected from other sources and not specifically at the direction of our Company, prior to obtaining the information, we verify in writing that the provider of the information has informed individuals of the ways and purposes for which our Company intends to use the information. If written verification cannot be obtained from the provider of the information, we use only anonymized or deidentified information, or prior to using Personal Information, we inform the affected individuals through a privacy notice or similar means of (1) the entity or entities of our Company responsible for processing the information, (2) the contact details of our Chief Privacy Officer and/or the regional/local Data Protection Officer, (3) what information our Company plans to use, (4) the purposes for which our Company plans to use it, (5) the legal basis for our processing, (6) with whom our Company will share it, (7) whether and how we will transfer the Personal Information to other countries, including identifying the relevant countries where feasible (8) how long our Company plans to retain it or the criteria by which we make that determination, (9) how they can ask a question, raise a concern or exercise their rights related to their Personal Information, (10) how they can withdraw any consent they have provided, (11) their right to lodge a complaint with a supervisory authority, (12) any obligation to provide Personal Information and the consequences of not doing so, (13) any automated decision-making, including profiling, that may be carried out, and (14) a link to this Policy, where possible and appropriate.
    • We ensure that the necessary transparency mechanisms, including, where possible, mechanisms that support individual rights requests, are designed into supporting technologies, and that third parties supporting the activity or process do not process information about people in ways that are inconsistent with what individuals have been told through a privacy notice or other verifiable means that we and others working for us will do with the information.
    • When we seek consent, we obtain and document evidence of consent in our supporting technologies.

    4. Purpose Limitation – We only use Personal Information in accordance with the Necessity and Transparency principles.

    • If new legitimate business purposes are identified for Personal Information that previously was collected, we either obtain the individual’s consent for the new use of Personal Information, or we ensure that the new business purpose is compatible with, including materially similar to, purposes described in a privacy notice or other transparency mechanism that was previously provided to the individual. We will determine compatibility based on (1) any link between the original purposes and the proposed new purpose, (2) the reasonable expectations of the individual, (3) the nature of the Personal Information, (4) the consequences of the further processing for the individual, and (5) the safeguards we have put in place.
    • We do not apply this principle to anonymized or deidentified information, or where we use Personal Information solely for historical and scientific research purposes and (1) an Ethics Review Committee, or other competent reviewer, has determined that the risk of such use to privacy and other rights of individuals is acceptable, (2) we have put in place appropriate safeguards to ensure data minimization, (3) the personal data is pseudonymized and (4) all other applicable Laws are respected.
    • We ensure that purpose limitation restrictions are designed into any supporting technology, including any reporting capabilities and downstream data sharing.

    5. Data Quality – We strive to maintain Personal Information accurate, complete and current, consistent with its intended use.

    • We ensure that periodic data review mechanisms are designed into supporting technologies to validate the data accuracy against source and downstream systems.
    • We ensure that Sensitive Information is validated as accurate and current prior to its use, evaluation, analysis, reporting or other processing that presents a risk of unfairness to people if inaccurate or outdated data are used.
    • Where changes are made to Personal Information by our Company or third parties working for our Company, we ensure that those changes are communicated to the relevant individuals in a timely manner, where reasonably possible.

    6. Security – We implement safeguards to protect Personal Information and Sensitive Information from loss, misuse, and unauthorized access, disclosure, alteration or destruction.

    • We have implemented a comprehensive information security program and apply security controls and safeguards that are based on the nature and sensitivity of the information and the risk level of the activity, taking into account current technology best practices and the cost of implementation. Our functional security policies include, but are not limited to, standards on business continuity and disaster recovery, encryption, identity and access management, information classification, information security incident management, network access control, physical security, and risk management.

    7. Data Transfer – We are responsible for preserving the privacy protections for Personal Information when it is transferred to or from other organizations or across country borders.

    (1) We transfer Personal Information within our Company if the following requirements are met:

    (a) the sharing is necessary to fulfill the purpose for which the Personal Information was originally collected or another legitimate interest of the Company; and (b) the purpose for which it is to be shared, and the fact that it will be shared, is consistent with the privacy notice or other transparency mechanism that was previously provided to the individual at the time the Personal Information was originally collected and the individual gave their consent where necessary; (c) where one of our Company subsidiaries acts solely on behalf of another of our Company subsidiaries in processing Personal Information; (d) where required by Law, those subsidiaries of our Company will execute an internal data processing agreement in accordance with Principle 8 of this Policy or; (e) where the IT infrastructure requires such transfer, provided all appropriate security and organizational measures are in place to make such transfer compliant.

    (2) We only transfer Personal Information to, or allow it to be processed by, third parties if the following requirements are met and we confirm that the third parties meet these requirements:

    • If the role of the third party is to process Personal Information for or on behalf of our company, before providing Personal Information to the third party or engaging the third party, we: (1) complete privacy due diligence to evaluate the privacy practices and risks associated with such third party, (2) obtain contractual assurances from those third parties that they will (i) process Personal Information pursuant only to our Company’s instructions, and in accordance with this Policy, including without limitation all eight (8) Privacy Principles and the other standards set forth in this Policy, and applicable Laws; (ii) that they will notify our Company promptly of any Privacy Incident, including any inability to comply with standards set forth in this Policy and applicable Laws, or Security Incident, and cooperate to promptly remediate any substantiated Incident and to address the individual rights set forth in Section 2 below; (iii) that they will not engage another company to process the Personal Information without our written authorization and without putting in place an agreement imposing equivalent data protection obligations; (iv) that they will securely delete or return to us all Personal Information after they have finished providing services to us or upon our request or direction; and (v) that they will permit our Company to audit and monitor their practices for compliance with these requirements for the duration of the processing. Additionally, if the third-party processes Personal Information that originates in a country or territory with a law that restricts the transfer of Personal Information, we will ensure that the transfer to the third party meets the requirements for cross-border data transfer described in (3) below.
    • If the role of the third party is to supply Personal Information to our Company, before obtaining Personal Information from the third party, we ensure that the transparency requirements for collecting Personal Information from other sources and not specifically at the direction of our Company are met, and we obtain contractual representations from the third party that it is not violating any Law or the rights of any third party by providing Personal Information to our company.
    • If the role of the third party is to receive information from our Company for processing that is not specifically at the direction of our Company, before providing information to the third party, we ensure that the information has been anonymized or deidentified, and we obtain written assurances from the third party that they will use it only for the specific business purposes defined in the agreement and in accordance with applicable Laws, and that they will not attempt to reidentify the information.
    • If the transfer to a third party is required to protect the individual’s legitimate interests or those of the Company, we may transfer the information: (1) for the purposes of fraud prevention or to enforce or protect the rights and properties of the Company, (2) for the protection of the personal safety of our employees or third parties on our property, and (3) to protect our assets by taking corrective security measures if we reasonably suspect that unlawful activity or serious misconduct has taken place.
    • If the third party is a target for acquisition or a controlling interest by our Company, (1) prior to entering into an agreement to acquire the third party or to acquire a controlling interest in the third party, we complete privacy due diligence to evaluate the privacy practices and risks associated with acquisition of that third party or a controlling interest in that third party, and (2) we enter into a data transfer agreement that specifies the terms and conditions under which Personal Information may be disclosed and the respective obligations of our company and the third party.
    • If the role of the third party is to acquire all or part of our Company’s business, prior to sharing any Personal Information in connection with a divesture of any part of our Company’s business, we (1) enter into a data transfer agreement that specifies the terms and conditions under which Personal Information may be disclosed to the purchaser, including appropriate limitations as to the permitted uses of the Personal Information and compliance with the standard set forth this Policy and applicable Law, (2) minimize sharing of data elements to that which is necessary, (3) obtain consent to share Personal Information or Sensitive Information in accordance with the Transparency and Purpose Limitation principles of this Policy, and (4) require the third party to notify our Company promptly of any applicable Privacy Incident, including any inability to comply with standards set forth in this Policy and applicable Laws, and to cooperate to promptly remediate any substantiated Incident or cease processing relevant Personal Information.

    (3) We transfer Personal Information across country borders, including to the United States of America (USA) where our Company is headquartered, by or on behalf of our Company in accordance with this Policy. We will apply this Policy to transfers of Personal Information from any other country or territory with a law that restricts the transfer of Personal Information, in addition to complying with any requirements imposed by such Laws (including the use of any mechanisms required for cross-border transfers to countries not having the same data protection standards than the originating country).

    8. Legally Permissible – We only process Personal Information if the requirements of applicable Laws have been met.

    While the other seven (7) privacy principles, as well as the individual rights requirements described below, are intended to ensure that the requirements of most privacy and data protection laws that apply to our business around the world have been met, in some countries, we need to meet additional requirements, including but not limited to the following:

    1) Where required, we will obtain specific forms of consent for certain processing of Personal Information, including but not limited to, approval of the processing by works councils and other labor unions;

    2) Where required, we will register processing of Personal Information with or seek the approval of the applicable privacy or data protection regulatory authority;

    3) Where required, we will provide broader rights (for example, of access and correction) than set forth in this Policy;

    4) Where required, we will further limit data retention periods for Personal Information;

    5) Where required, we will enter into agreements containing specific contractual clauses, including agreements for cross-border data transfer to third parties; y

    6) Where required, we will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    In the event of a conflict between this Policy and an applicable law, the standard that provides more protection to individuals will prevail.

  2. We will promptly address individual rights requests to access, amend, correct or delete Personal Information, to object to the processing of Personal Information about them, or to exercise other rights regarding their Personal Information.
    1. Access, Correction, Deletion, and other rights – Under Laws in most countries in which we operate, individuals have a right to access Personal Information about themselves, and to amend, correct or request deletion of Personal Information that is inaccurate, incomplete or outdated. We will honor all requests to access, correct and delete Personal Information from all individuals in accordance with Section 3a below and as allowed by applicable Law. If a request for access, correction or deletion is governed by an applicable Law that provides greater protection to individuals, we will ensure that the additional requirements of that Law are met.

      In some countries, individuals may be entitled to other rights with respect to Personal Information about themselves, such as a right to restrict processing, to object to processing (see also Section 2b below), and to have their data transferred to another service provider. We will honor the exercise of data rights in accordance with applicable Laws. Some rights such as deletion may be limited according to other regulatory or legal requirements or the necessity to comply with local compliance reporting; in such case, we will inform you about these limitations as applicable.

    2. Choice – Consistent with our privacy values of “Respect” and “Trust,” we honor individual requests to object to Personal Information processing, including, but not limited to opting out of programs or activities in which they previously agreed to participate, processing of Personal Information about them for direct marketing communications, communications targeted to them based on Personal Information about them, and any evaluation of or decisions about them, which has the potential to significantly affect them, made by use of automation or algorithms.
      1. Except where prohibited by Law, we may deny the choice where a particular request would impede our Company in its ability to: (1) comply with a Law or an ethical obligation, including where we are required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, (2) investigate, make or defend legal claims, and (3) perform contracts, administer relationships, or engage in other permitted business activities that are consistent with the Transparency and Purpose Limitation principles and were entered into in reliance on the information about people in question. Within fifteen (15) business days of any decision to deny a choice request in accordance with this Policy, we will document and communicate the decision to the requestor unless otherwise required by applicable law.
  3. We will promptly respond to and escalate all privacy-related questions, complaints, concerns and any potential Privacy Incident or Security Incident.
    1. Any individual about whom we process Personal Information within the scope of this Policy can raise a question, complaint or concern to our Company at any time, including a request for a list of all subsidiaries of our Company that are subject to this Policy. We expect that our employees, and others who work on behalf of our Company, will provide prompt notice if they have a reason to believe that an applicable Law may prevent them from complying with this Policy. Any question, complaint or concern raised by an Individual, or any notice provided by an employee or any other person who works on behalf of our company, should be directed to the Global Privacy Office:
      1. By e-mail for individuals residing in the European Economic Area (EEA) to: euprivacydpo@organon.com
      2. Otherwise by e-mail to: privacyoffice@organon.com By postal mail to: Chief Privacy Officer, Organon & Co., 30 Hudson Street, Jersey City, NJ 07302.
    2. Employees and contractors are required to promptly inform the Global Privacy Office, or the designated Business Practice Manager for their business area, of any questions, complaints or concerns related to our Company’s privacy practices.
    3. The Global Privacy Office will review and investigate, or will work with the Office of Ethics, Legal and Compliance colleagues, to investigate, all questions, complaints or concerns related to our Company’s privacy practices, whether received directly from employees or other individuals or through third parties, including, but not limited to regulatory agencies, accountability agents and other government authorities. We will respond to the individual or entity that raised the question, complaint or concern to our Company within thirty (30) calendar days unless a Law or the third party requestor requires a response in a shorter period of time or unless circumstances, such as a concurrent government investigation, require a longer time period, in which case the individual or third party requestor will be notified in writing as soon as practicable of the general nature of the circumstances contributing to the delay.
    4. The Global Privacy Office, in coordination with Legal and Compliance colleagues, will cooperate in response to any inquiry, inspection or investigation of a privacy regulatory authority.
    5. For complaints that cannot be resolved between our Company and the individual who raised the complaint, our Company has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to this Policy; however, at any time, individuals resident in the European Economic Area (EEA) or individuals about whom Personal Information is subject to the applicable Law of the EEA and transferred outside of the EEA, may also rely on standard 3.f. below:
      1. For disputes involving the transfer of Personal Information pursuant to our Company’s compliance with the Asia Pacific Economic Cooperation (“APEC”) Cross-Border Privacy Rules (“CBPRs”) amongst the APEC Economies, our Company has agreed to dispute resolution by our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
    6. All individuals residing in the EEA, or individuals about whom Personal Information is subject to the data protection Law of the EEA and transferred outside of the EEA, about whom information is processed pursuant to this Policy have the right, where the EU Standard Contractual Clauses are used to transfer their Personal Information, at any time, to enforce the requirements of the Standard Contractual Clauses as third party beneficiaries, including the right to bring a judicial action to seek remedies for breach of his or her rights under the Standard Contractual Clauses and the right to receive an award for damages resulting from such breach. Individuals residing in the EEA or individuals about whom Personal Information is subject to the data protection Law of the EEA and transferred outside of the EEA (including to the USA), may bring a claim or a complaint under the Standard Contractual Clauses, against the Company with the competent Data Protection Authorities (in particular in the Member State of his/her habitual residence, place of work or place of the alleged infringement). The contact information for data protection authorities may be found here: Members | European Data Protection Board (europa.eu)
    7. Our Company will respond to the individual or entity that raised the question, complaint or concern to our Company within the time period allotted by applicable Law unless a thirdparty requestor requires a response in a shorter period of time or unless circumstances require a longer time period, in which case the individual or third-party requestor will be notified in writing.
  4. We are accountable for upholding our privacy values and standards.
    1. The subsidiary of our Company accountable for an action that gives rise to a substantiated Privacy Incident or Security Incident is financially responsible for the amount of any claim for damages or fine or penalty arising out of the Privacy Incident or Security Incident.
      1. In coordination with and at the direction of the Global Privacy Office, the European Data Protection Officer is responsible for ensuring that the necessary actions are taken to address any alleged violations of this Policy by subsidiaries of our Company outside of the EEA affecting individuals residing in the EEA or individuals about whom Personal Information is subject to the data protection Law of the EEA and transferred outside of the EEA.

Oversight and Monitoring

In order to provide assurance to regulators and other stakeholders that our Company is accountable for its commitment to ethical and responsible privacy practices, the Company maintains an extensive oversight and monitoring governance group, headed by a Chief Privacy Officer with a dedicated Global Privacy Office (GPO), with oversight by a Privacy and Data Protection Board, an assigned EU Data Protection Officer, country DPO’s where required by law or local authorities, and Business Practice Managers, who are appointed by Senior Leaders and serve as liaisons between the Global Privacy Office and the organizational areas in which they work.

Terms You Need to Know

  • Anonymized. The alteration, truncation, obliteration or other redaction or modification of Personal Information so as to render it irreversibly incapable of being used to identify, locate or contact an individual, either alone or in combination with other information.
  • Company. Organon & Co., its successors, subsidiaries and divisions worldwide, excluding joint ventures to which our Company is a party.
  • Deidentified. The removal of direct and indirect personal identifiers, often preserving the original identification data separately.
  • Law. All applicable laws, rules, regulations, and orders of opinions having the force of law in any country in which our Company operates or in which Personal Information is processed by or on behalf of our Company. This includes all privacy frameworks under which our company has been approved or certified including the Asia Pacific Economic Cooperation (“APEC”) Cross-Border Privacy Rules (“CBPRs”).
  • Personal Information. Any data relating to an identified or identifiable individual, including data that identifies an individual or that could be used to identify, locate, track, or contact an individual. Personal Information includes both directly identifiable information such as a name, identification number or unique job title, and indirectly identifiable information such as date of birth, unique mobile or wearable device identifier, telephone number as well as key-coded data, online identifiers such as IP addresses or any personal activities, behavior, or preferences which may be collected to provide services or products.
  • Privacy Incident. A violation of this Policy or a privacy or data protection Law and includes a Security Incident. Determinations of whether a privacy incident has occurred and whether it should be elevated to a Personal Data Breach shall be made by the Global Privacy Office, Business Technology Risk Management (BTRM), and Legal.
  • Processing. Performing any operation or set of operations on information about people, whether or not by automatic means, including, but not limited to, collecting, recording, organization, storage, access, adaptation, alteration, retrieval, consultation, use, evaluation, analysis, reporting, sharing, disclosure, dissemination, transmission, making available, alignment, combination, blocking, deleting, erasure or destruction.
  • Personal Data Breach. A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information, or our Company’s reasonable belief of the same. Access to Personal Information by or on behalf of our Company without the intent to violate this Policy does not constitute a Personal Data Breach, providing that the Personal Information accessed is further used and disclosed solely as permitted by this Policy.
  • Security Incident. An information security incident is made up of one or more unwanted or unexpected information security events that could possibly compromise the security of information and weaken or impair business operations.
  • Sensitive Information. Any type of information about people that carries an inherent risk of potential harm to individuals, including information defined by law as sensitive, including, but not limited to information related to health, genetics, biometrics, race, ethnic origin, religion, political or philosophical opinions or beliefs, criminal history, precise geo-location information, bank or other financial account numbers, government-issued identification numbers, children who are minors, sex life, sexual orientation, trade union affiliation, insurance, social security and other employer or government-issued benefits.
  • Third party. Any legal entity, association or person that is not owned by our Company, or in which our Company does not have a controlling interest, or who is not employed by our Company. No affiliate of the Company should be deemed as a third party.

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of applicable Law. A notice will be posted on our company’s privacy web page https://www.organon.com/privacy for sixty (60) calendar days whenever this Policy is changed in a material way.