PRIVACY POLICY
Effective Date: September 2025
Millicent Pharma Limited (“Millicent Pharma” “we,” “our,” or “us”), provides this privacy policy (“Privacy Policy”) to describe how we collect, use, and share the information of individuals who visit our websites at us.intrarosa.com, femring.com, femlyv.com, millicentpharma.com or any other website we own or operate or that links to this Privacy Policy (the “Site(s)”). Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as terms defined in our Terms of Service.
1. Information Collection
When using our Sites or interacting with us, you may voluntarily provide information about yourself, including your name, email address, and any other information you choose to provide. We collect this information when you send an email to us requesting information or interact with us for any other purpose.
We (and other entities) automatically collect information relating to your interactions with us and our Sites, including browser type, IP address, pages visited and other activities on the Sites, device type, and time and date of visit, and other information we collect through the use of cookies and similar technology. See the “Digital Advertising & Analytics” section of this privacy policy to learn more about the use of this information and the choices available to you.
2. Information Use
We may use your information for any lawful purpose, including the following:
- To respond to your inquiries, including reports regarding our products;
- To operate and improve our services, including to provide better services, products, and opportunities to our customers and visitors to our Sites;
- To operate, personalize, and improve our Sites, including for analytics purposes;
- To promote and market our products and services, including to send surveys, promotions, advertisements, and marketing materials that may be of interest to you;
- To comply with the law and to maintain the security of our Sites; or
- With your consent, or as otherwise disclosed at the time information is collected.
We may use information that has been de-identified or aggregated without limitation.
3. Information Sharing
We may share the information we collect with third parties, including the following:
- With service providers who perform various functions on our behalf or with our legal or business advisors;
- With any affiliates or joint venture partners that we may have in the future;
- As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
- Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity;
- With your consent or as otherwise disclosed at the time of data collection or sharing.
We may share information that has been de-identified or aggregated without limitation.
4. Digital Advertising & Analytics
We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Sites and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.
You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.
We may work with third parties that collect data about your use of our Sites and other sites or apps over time for non-advertising purposes. Millicent Pharma uses Google Analytics and other third-party services to improve the performance of our Sites and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Sites, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.
Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Sites may not function as intended.
5. Third-Party Links and Tools
Our Sites may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy policies of other websites or apps that you use to learn about their data practices.
Our Sites may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Sites, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.
6. Your Choices
We may send promotional communications (including emails and text messages), newsletters, and similar communications. You may opt out of receiving certain promotional communications from us by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive. Unsubscribe requests for e-mail may take up to 10 business days to be effective and will not apply to messages that you request or that are not commercial in nature.
7. Your California Privacy Rights
Under the California Consumer Protection Act (“CCPA”), California residents have certain rights with respect to the personal information collected by businesses. This section contains disclosures required by the CCPA and applies only to “personal information” about California consumers that is subject to the CCPA (“California Personal Information”).
California Personal Information We Collect and Share for a Business Purpose. We collect the following categories of California Personal Information:
| Categories of California Personal Information Collected | Disclosed for business purposes to the following categories of third parties: |
|---|---|
| Personal and online identifiers (such as first and last name, email address, or unique online identifiers) | All categories listed below. |
| Categories of information described in Section 1798.80(e) of the California Civil Code (such as physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information) | All categories listed below. |
| Characteristics of protected classifications under California or federal law (such as race or gender) | All categories listed below. |
| Commercial or transactions information (such as records of personal property or products or services purchased, obtained, or considered) | All categories listed below. |
| Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement) | All categories listed below. |
| Biometric information (such as call recordings) | All categories listed below. |
| Personal information regarding health | Service providers; affiliates. |
| Inferences drawn from the above information about your predicted characteristics and preferences | All categories listed below. |
| Other information about you that is linked to the personal information above. | All categories listed below. |
We share California Personal Information for targeted advertising purposes but do not otherwise engage in “sales” of California Personal Information as defined by state laws. Additionally, we do not knowingly sell or share California Personal Information of individuals under 16.
Some of the categories of California Personal Information listed in the table above are considered sensitive personal information under the CCPA—such as information regarding health or demographic information about race or gender. We do not use or disclose sensitive personal information, as defined by the CCPA, for purposes other than those specified in the CCPA.
Categories of Sources. We and our service providers, acting on our behalf, collect California Personal Information from the following categories of sources:
- From consumers;
- From service providers we have engaged to provide services to us or on our behalf;
- From our affiliates; and
- From non-affiliated third parties, such as pharmacies or copay programs that may collect personal information on our behalf.
Why We Use and Disclose California Personal Information. We and our service providers, acting on our behalf, use and disclose California Personal Information we collect for our commercial and business purposes, as further described in this Privacy Policy. These purposes include, without limitation:
- Our commercial purposes, including marketing and facilitating transactions.
- Our business purposes as identified in the CCPA, which include
- Auditing related to our interactions with you;
- Detecting and protecting against security incidents, fraud, and illegal activity;
- Debugging;
- Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
- Internal research for technological improvement;
- Activities to maintain and improve our services; and
- Other one-time uses.
We may use and share de-identified information to the extent permitted by applicable law. When we use de-identified information, we maintain and use the information in de-identified form and do not attempt to re-identify it, except to check whether our deidentification processes satisfy the requirements of applicable law.
Retention of California Personal Information. We retain California Personal Information in identifiable form only for as long as necessary to fulfill the purposes for which the California Personal Information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements, or to satisfy any similar essential purposes. To determine the appropriate retention period for California Personal Information, we consider the amount, nature, and sensitivity of the California Personal Information, the potential risk of harm from unauthorized use or disclosure of California Personal Information, the purposes for which we process California Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. Once the retention period expires and if not otherwise required to retain information by law, we will delete or de-identify California Personal Information.
Recipients of California Personal Information. We disclose the categories of California Personal Information designated above for business purposes to the categories of third parties listed below:
- Service providers;
- Affiliates not under the Millicent brand; and
- Data analytics providers.
We disclose certain categories of California Personal Information indicated above for commercial purposes to advertising companies and networks.
Your Rights Regarding California Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your California Personal Information, subject to certain exceptions and limitations:
- The right to access the categories and specific pieces of personal information we have collected about you; the categories of sources from which we collected your personal information, our purposes for collecting your personal information, the categories of your personal information that we have disclosed for a business purpose, and the categories of third parties with which we have shared personal information.
- The right to receive a portable and readily usable copy of the personal information we have collected about you, to the extent feasible.
- The right to correct inaccuracies in the personal information we have collected about you.
- The right to request that we delete the personal information we have collected from you.
- The right to opt out of (i) the sharing of personal information for targeted advertising; or (ii) the sale of personal information. Please note that if you opt out of certain practices, we may be unable to provide you with some services. Additionally, we do not knowingly sell or share California Personal Information of individuals under 16.
- The right not to receive discriminatory treatment for the exercise of the above privacy rights.
To exercise any of the above rights, please contact us:
- Online at Privacy Request Form
- By phone at 1-877-514-2221
- By email at privacy@millicentpharma.com
Verification Process and Required Information: Note that we may need to request additional information from you to verify your identity or understand the scope of your request to access, correct, or delete personal information. You will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, basic contact information like your name and phone number.
Authorized Agent: You may also designate an authorized agent to make requests on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.
8. Changes to Our Privacy Policy
If our information practices change, we will post these changes on this page. We encourage you to visit this page periodically to learn of any updates.
9. Contact Us
If you have questions, comments, or concerns about this Privacy Policy, please contact us at: privacy@millicentpharma.com.