Last Revised: August 20, 2026
Introduction
Galt Pharmaceuticals, LLC (referred to as “Company,” “Galt,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy. This privacy policy (“Privacy Policy”) describes the types of information we may collect from you, or that you may provide, when you visit the website Norgesic.com (our “Site”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Site is intended for patients and visitors in the United States.
This Privacy Policy applies to information we collect on this Site, in email and other electronic messages between you and this Site, and through our sample request form, which is hosted on our behalf by a third-party form service, whether you reach that form through this Site or directly. It does not apply to information collected offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries), information you provide through voluntary responses to emails, or information collected by any third party whose website, application, or content may link to or be accessible from this Site.
Please read this Privacy Policy carefully. By accessing or using this Site, you agree to it. If you do not agree with our policies and practices, your choice is not to use our Site. This policy may change from time to time; your continued use of this Site after we post changes is deemed acceptance of those changes, so please check this page periodically for updates.
Children Under the Age of 16
Our Site is not intended for children under 16 years of age, and no one under 16 may provide any personal information on the Site. We do not knowingly collect personal information from children under 16, and we do not sell or share the personal information of consumers under 16 years of age. If you are under 16, do not use or provide any information on this Site. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will use commercially reasonable means to delete that information. If you believe we might have any information from or about a child under 16, please contact us by emailing galtdirect@galtrx.com or by calling (855)-965-2783.
Information We Collect and How We Collect It
This Site collects very little information. What we do collect falls into two groups: information you give us, and information our web servers record automatically.
Information You Provide to Us
- Information you enter in the sample request form on our Request Samples page. That form is intended for licensed healthcare professionals only, and asks for your name, professional credentials and license information, practice address, contact details, signature, and date, so that we can verify your eligibility and ship the samples you request.
- Records and copies of your correspondence, including your email address, if you choose to contact us.
Galt does not knowingly collect, request, or obtain any personally identifiable information related to your medical history, health, or finances. Nothing on this Site is intended to solicit any such information, and by interacting with our Site you agree not to provide any sensitive or personally identifiable medical, health, or financial information.
Information We Collect Automatically
As you navigate through and interact with our Site, our servers record standard web server and error log data, including your IP address, the approximate general location it suggests, your operating system and browser type, the resources you access and use on the Site, and the dates and times of your visits. Some of this information, such as your IP address, is treated as personal information under applicable privacy laws.
This information helps us improve our Site, diagnose and repair errors, protect the Site against attacks and abuse, and deliver a better service, including by enabling us to estimate our audience size and usage patterns. We do not use it to build advertising or marketing profiles.
Your IP address is also received by the third-party provider that hosts our sample request form whenever our Request Samples page is opened. See “The Sample Request Form and Your IP Address” below.
Cookies and Other Technologies
Cookies on this Site come from one place only: the sample request form on our Request Samples page, which is hosted for us by an outside provider and sets its own cookies when that page opens. Those cookies are itemized in the table below. Galt sets no cookies of its own anywhere on this Site, and we use no advertising, analytics, or tracking technologies. We never use cookies to advertise to you, to build a profile about you, or to track you across other websites or over time.
Apart from that form, no third-party content is loaded into our pages, so browsing the rest of this Site does not disclose your IP address or your browsing activity to any third party.
Cookies Used on This Site
| Cookie | Set by | Purpose | Typical duration |
|---|---|---|---|
| PHPSESSID, mf_has_cookie | MachForm, the form host, on galt.forms-db.com, via the embedded sample request form | Session handling for the embedded form, and a check that your browser accepts cookies. The provider sets these for cross-site use, so your browser stores them while the form is embedded in our pages. | Session to 1 day |
| AWSALB, AWSALBCORS, AWSALBTG, AWSALBTGCORS | MachForm’s hosting provider, on galt.forms-db.com, via the embedded sample request form | Load balancing, so that repeated requests reach the same server | Approximately 7 days |
All of these cookies are set by the form provider rather than by Galt, and all of them are functional: they keep the form working and route your requests to the right server. None of them are advertising or analytics cookies, and none of them are used to profile you or to track you across other websites or over time.
We do not use tag managers, advertising or conversion pixels, web beacons, social media widgets, session-replay or heatmap tools, or device fingerprinting on this Site. The sample request form is not protected by a CAPTCHA service, and it loads its images, fonts, and scripts from its own provider’s domains rather than from Google or any other third party. Neither the form nor any other part of this Site writes entries to your browser’s local storage or session storage.
The Sample Request Form and Your IP Address
The form on our Request Samples page is hosted for us by a third-party online form service on the domain galt.forms-db.com. Because the form is embedded directly in the page, your browser connects to that provider as soon as the page opens. At that moment — before you type anything, whether or not you go on to complete the form, and whether or not you are a healthcare professional — the provider receives and processes your IP address along with your browser and device information, and sets the cookies listed in the table above on your device.
If you do submit the form, the information you enter — including your name, professional credentials and license information, practice address, contact details, and signature — is transmitted to and stored by that provider before being made available to us.
That provider acts as our service provider and is bound by contract to use the information only to provide the form service to us, and not for its own purposes. Because the connection to the provider happens when the page opens rather than when the form is submitted, the only way to avoid it entirely is not to open the Request Samples page. You can instead request samples by contacting the GaltDirect™ Help Desk at (855)-965-2783 or galtdirect@galtrx.com.
You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. Because the sample request form is the only source of cookies associated with this Site, refusing them will not affect any other part of the Site.
How We Use Your Information
We use the information we collect about you, or that you provide to us, including any personal information:
- To present our Site and its contents to you, and to provide the information, products, or services you request.
- To verify that a person requesting drug samples is an eligible licensed healthcare professional, and to fulfill and document that request.
- To secure the Site, to detect and investigate fraud and abuse, and to diagnose and repair errors.
- To comply with our legal and regulatory obligations, including the recordkeeping rules that apply to prescription drug samples.
- To fulfill any other purpose for which you provide the information, in any other way we describe when you provide it, or for any other purpose with your consent.
Notice at Collection – Categories of Personal Information
The table below summarizes, using the categories defined in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), the personal information we have collected through this Site in the preceding twelve months, why we collect it, and who receives it. Retention for every category is described under “How Long We Keep Your Information” below.
| Category of personal information | What we collect | Source | Purpose | Who receives it |
|---|---|---|---|---|
| Identifiers | Real name, postal and practice address, email address, telephone number, IP address | Directly from you; automatically from your device | Respond to you; display the sample request form; verify sample eligibility and ship samples; Site security and error diagnosis | Service providers (form host, shipping vendor, hosting/IT); affiliates |
| Customer records information (Cal. Civ. Code § 1798.80(e)) | Name, signature, address, telephone number, professional license information | Directly from you, via the sample request form | Authorize, fulfill, and document a drug sample request; regulatory recordkeeping | Service providers (form host, shipping vendor); affiliates |
| Professional or employment-related information | Professional credentials, license type and number, practice affiliation | Directly from you, via the sample request form | Verify eligibility to receive drug samples; regulatory recordkeeping | Service providers (form host, shipping vendor); affiliates |
| Internet or other electronic network activity information | Pages and resources visited, dates and times of visits, browser type, operating system | Automatically from your device | Operate, secure, troubleshoot, and improve the Site; estimate audience size | Service providers (hosting/IT) |
| Geolocation data (approximate only) | General location inferred from your IP address | Automatically from your device | Site security; audience estimation | Service providers (hosting/IT) |
We do not collect the other categories of personal information listed in the CCPA — protected classification characteristics, commercial information, biometric information, sensory data such as audio or video recordings, education information, or inferences drawn to create a profile about you. We also do not collect, use, or disclose sensitive personal information as that term is defined in the CCPA, so the right to limit the use and disclosure of sensitive personal information does not apply to us. We do not use or disclose any personal information for purposes other than those disclosed in this Privacy Policy.
Disclosure of Your Information
We may disclose aggregated or de-identified information that does not identify any individual, such as the number of visitors to this Site, without restriction.
We may disclose personal information that we collect, or that you provide, as described in this Privacy Policy:
- To our parent company, subsidiaries, and affiliates.
- To contractors, service providers, and other third parties we use to support our business, who are bound by contractual obligations to keep personal information confidential and to use it only for the limited purposes for which we disclose it. This includes the service that hosts our sample request form and the vendor that ships samples to you.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Galt's assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal information we hold about our Site's users is among the assets transferred.
- To fulfill the purpose for which you provide it, for any other purpose we disclose when you provide it, or with your consent.
- To comply with any court order, law, or legal process, including responding to any government or regulatory request; to enforce or apply our Terms of Use; or where we believe disclosure is reasonably necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
In the preceding twelve months, we disclosed the categories of personal information listed in the table above to our service providers and affiliates for the business purposes described in this Privacy Policy.
We do not sell your personal information, and we do not share it for cross-context behavioral advertising or targeted advertising. We have not done so in the twelve months preceding the revision date at the top of this page. We also do not disclose personal information collected through this Site to third parties for those third parties' own direct marketing purposes.
Any non-personal communication or material you transmit to the Site by electronic mail or otherwise — including data, questions, comments, or suggestions — is, and will be treated as, non-confidential and non-proprietary, and may be used by the Company for any purpose. This does not apply to personal information, which we handle only as described in this Privacy Policy. Any personal information you provide is provided voluntarily and is not required to access or use this Site.
How Long We Keep Your Information
We keep personal information only for as long as reasonably necessary for the purpose it was collected for, and then delete it or de-identify it. Because this Site collects very little information, we do not apply a single fixed retention period to everything. In deciding how long to keep information, we consider how long we need it in order to respond to you or to complete what you asked us for; any period we are required to keep records for by law or regulation, including the recordkeeping rules that apply to prescription drug samples; and whether we still need it to resolve a dispute or enforce our agreements. Web server and error logs are kept only for as long as they are needed for security monitoring and troubleshooting. Where a legal hold or a regulatory obligation requires us to keep information longer, we will do so, and will delete it when that obligation ends.
Your Privacy Rights
Depending on where you live, privacy laws — including the CCPA — may give you rights over the personal information we hold about you. We extend the following rights to all visitors to this Site, regardless of where you live:
- To know. You may ask us to tell you what personal information we have collected about you, the categories of sources it came from, the business purpose for collecting it, the categories of third parties to whom we disclosed it, and the specific pieces of personal information we hold.
- To delete. You may ask us to delete personal information we collected from you. We will do so, and direct our service providers to do so, unless we are required or permitted to keep it — for example, to comply with drug sample recordkeeping obligations, to detect security incidents, or to establish or defend legal claims. If we deny a request in whole or in part, we will tell you why.
- To correct. You may ask us to correct inaccurate personal information we hold about you.
- To obtain a copy. Where you ask us what personal information we hold, you may receive it in a readily usable, portable format where technically feasible.
- To opt out of the sale or sharing of your personal information. As stated above, we do not sell or share personal information, so there is nothing to opt out of, and no third party collects information through this Site in order to serve you interest-based advertising. There is no industry-agreed standard for how websites should respond to browser “Do Not Track” signals, and this Site does not currently respond to them. If we ever introduce analytics or advertising technologies to this Site, we will update this Privacy Policy first, and we will treat opt-out preference signals sent by your browser, such as Global Privacy Control, as valid requests to opt out of the sale and sharing of your personal information.
- To limit the use and disclosure of sensitive personal information. We do not collect or process sensitive personal information, so this right does not apply to us.
- To be free from discrimination. We will not deny you goods or services, charge you a different price, or provide a different level or quality of service because you exercised any of these rights. We do not offer financial incentives in exchange for personal information.
How to Submit a Request
To exercise any of these rights, email galtdirect@galtrx.com with “Privacy Rights Request” in the subject line, or call us toll-free at (855)-965-2783. Please tell us which right you wish to exercise and give us enough information to locate any records we may hold about you. If you need this Privacy Policy or a response to your request in an alternative, accessible format, tell us and we will provide one.
How We Verify and Respond
Before we act on a request, we must verify that it comes from you. Because this Site collects so little information, this is usually straightforward: we will ask you to confirm details that match information we already hold, such as the email address you corresponded with us from. We will not ask for more information than is necessary to verify you, and we will use anything you provide for verification only for that purpose. You may also use an authorized agent to submit a request, in which case we will ask the agent for written permission signed by you. We will confirm receipt of your request within 10 business days and respond within 45 days; if we need more time, we will tell you and may take up to an additional 45 days. If we decline to act on your request, we will explain why, and you may appeal by replying to our response.
Data Security
We use commercially reasonable means to protect any personal information you provide. However, the transmission of information via the internet is not completely secure, and we cannot guarantee the security of personal information transmitted to our Site. Any submission of personal information is at your own risk, and we are not responsible for circumvention of any privacy settings or security measures contained on the Site.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page and to update the “Last Revised” date at the top. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Site's home page. We review this Privacy Policy at least once every twelve months. You are responsible for periodically visiting our Site and this Privacy Policy to check for any changes.
Other Terms
Third party websites linked to from this Site may each have different terms of use, privacy policies, and practices. You should review them carefully to determine how each site may use any personal information you provide. This Privacy Policy applies solely to information collected through the Site and not through any other website or source.
In addition to the rights and privileges described in this Privacy Policy or the Terms of Use (hereby incorporated herein), Galt Parties reserve the right to electronically monitor areas of the Site and may disclose any information, content, or records of any kind if required to do so by law, regulation, or government request, or if such disclosure is necessary or appropriate to operate the Site or to protect our rights or property, or the rights of users, partners, affiliates, licensors, or other third parties.
You expressly agree that the exclusive jurisdiction for any dispute with Galt Parties, or in any way relating to your use of the Site, shall be the courts in Cobb County in the State of Georgia, and you expressly consent to the exercise of personal jurisdiction there. This Privacy Policy shall be construed under and governed by the laws of the State of Georgia, without respect to its conflict of laws principles. Nothing in this paragraph limits any right you have under applicable privacy law, or your ability to submit a complaint to a regulator. If any provision of this Privacy Policy is found unenforceable by a court of competent jurisdiction, the invalidity of that provision shall not affect the validity of the remaining provisions, and no waiver of any term or condition shall be deemed a further or continuing waiver of that or any other term or condition. This Privacy Policy and the Terms of Use for this Site constitute the entire agreement between you and Galt with respect to the use of the Site.
Contact Us
If you have any questions or comments regarding this Privacy Policy or our privacy practices, or to submit a privacy rights request, please contact Galt Pharmaceuticals, LLC by emailing galtdirect@galtrx.com or by calling (855)-965-2783.