Privacy Policy

This site is owned by a pharmaceutical company (“Sponsor”). The Sponsor is committed to maintaining the accuracy, security, and privacy of Personal Information in accordance with applicable Canadian privacy laws. This policy applies to the collection, use of, and disclosure of Personal Information by the Sponsor. This policy, and the website(s) on which this policy appears, are intended for Canadian residents.

This Privacy Policy is a statement of principles and guidelines concerning the protection of Personal Information of our customers, service providers, and other individuals ("you").

BY SUBMITTING PERSONAL INFORMATION TO THE SPONSOR OR ITS AGENTS AND SERVICE PROVIDERS, THROUGH ANY MEANS, YOU AGREE THAT WE MAY COLLECT, USE, AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY APPLICABLE LAWS. Subject to legal and contractual requirements, and reasonable notice, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting the Sponsor's Privacy Officer using the contact information provided below. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

If you provide us with the Personal Information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such individual (or, if such individual is a minor in their jurisdiction of residence, from their parent or legal guardian) to enable us to collect, use, and disclose such Personal Information for the purposes set forth in this Privacy Policy.

Canadian privacy laws define Personal Information broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, Personal Information means information about an identifiable individual, as may be defined from time to time in applicable privacy laws (“Personal Information”). Personal Information includes personal health information which you provide to us or ask others to provide to us.

The types of Personal Information that the Sponsor may collect, use, and disclose about you includes (where applicable) your name, address, telephone number and facsimile number, cellular telephone number, email address, date of birth, insurance information, name of your physician, payment information, other contact information, and possibly information about your health. Some of our websites might require you to register in order to log in, in which case you will be required to provide personal information about yourself to us. Typically, the information we ask for includes some of the following, but this list is not exhaustive:

• Contact details, such as your name and email/postal address.
• Basic information about you, such as age and gender.
• Health and treatment data, including biometric information.
• Other information may also be requested, when relevant, and could include information about lifestyle or the household you live in as these impact aspects of managing medical conditions, or information regarding your education and employment history if you are seeking a position with us.

Whenever we ask you for any Personal Information that can be used to identify you as an individual, we provide an explanation as to why we gather the information, how we gather it, how we store it, and how we plan on treating and using it.

Except as described in this Privacy Policy or as may be permitted or required by applicable law, we will only gather Personal Information about you if you specifically agree to “opt-in,” i.e. you explicitly give us your consent to collect this information regarding you.

We will only gather and store Personal Information for the purpose stated during the gathering process and for such other purposes permitted or required by applicable law. When we finish processing your information for the stated purpose, we will erase and destroy it, following any legal or the Sponsor's retention periods, to help ensure your privacy.

There is always a lot of information that a company can ask you for, but the Sponsor will only ask for information where there is a clear and necessary need for that information, which is clearly and adequately explained to you.

The Sponsor limits the collection, use, and disclosure of your Personal Information, both in the amount and type of Personal Information, to that which is necessary to fulfill the purposes identified within this Privacy Policy or otherwise disclosed to you. We will identify the purposes for which your Personal Information is collected at or before the time your Personal Information is collected.

In general, the Sponsor collects, uses, and discloses Personal Information in order to provide our customers with our products and services, including to administer service contracts. More specifically, the Sponsor may collect, use, and disclose your Personal Information for the following purposes:

• to providers, financial institutions, and affiliates, in order to provide ongoing products and services, administer accounts, make and receive payments, and fulfill contractual obligations;
• to communicate with, understand, and respond to website visitors, customers, and potential customers’ needs and preferences, and improve the website experience;
• to conduct surveys, promotions, research, and statistical analysis;
• to facilitate customer service assistance;
• to distribute our newsletters, promotional information, and other material to registrants that have voluntarily enrolled in our mailing list and/or emailing list;
• to develop, enhance, market, sell, provide, and inform you of the Sponsor's products and services;
• to communicate with you regarding other consulting or business opportunities;
• to update and verify our databases and information provided by third parties;
• to develop and manage our databases;
• to handle or conduct litigation and/or investigations, and comply with government (regulatory, judicial, legislative) requests or orders;
• to respond to your requests, questions, or inquires;
• to create a record of complaints and adverse event reports relating to our products and reporting these to the relevant regulators, related companies, or other third parties;
• to administer disease awareness and management programs, or similar programs;
• to provide patient support and/or meetings;
• to conduct market research, including, without limitation, with relation to health economic data and other demographic matters; in the case of healthcare professionals, supplying you with clinical evaluation materials regarding our products, administering clinical trials, continuing education, conferences, panels, or seminars you agree to participate in;
• to otherwise operate our business in the normal course and manage risks, including for auditing and security purposes
• to create aggregated, de-identified information for analytical or reporting purposes, as permitted by, and/or to comply with, any legal or regulatory requirements or provisions;
• to evaluate you for a position to which you have applied, or other positions that may become available in the future, and for any other purpose to which you consent.

We will not sell, lease, or rent your Personal Information or our customer lists.

We disclose Personal Information in accordance with this Privacy Policy, or for the purpose(s) for which you have given consent.

We keep your Personal Information, questions, and transactions with us confidential, and we employ the appropriate security safeguards.

However, from time to time, the Sponsor may disclose your Personal Information to:

• service providers, including an organization or individual retained by the Sponsor to perform functions on its behalf, including, but not limited to, marketing, data processing, document management, and office services;
• service providers providing offsite servers to store information;
• to entities within the Sponsor Network of Companies to carry out the purposes indicated in this Privacy Policy;
• a person who, in the reasonable judgment of the Sponsor, is providing or seeking the information as your agent;
• any other third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

We reserve the right to transfer any Personal Information we have about you in the event that we merge with or are acquired by a third party. We may also disclose your Personal Information to third parties if we have reason to believe that disclosing such information is necessary to: (i) conduct investigations of possible breaches of law or policies; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) to protect our rights, safety, or property; or (iv) to investigate security breaches or cooperate with government authorities pursuant to a legal matter.

Personal Information you provide to us may be transferred outside of your province of residence, and outside of Canada, including to our offices in the U.S., the European Union, and/or Japan. You agree that by providing us with your Personal Information, your Personal Information may be subject to the laws of such jurisdictions, regulations, and/or court orders and may be disclosed to third parties or authorities in complying with the laws, regulations, and/or court orders of such jurisdictions.

Further, please note that certain governmental agencies in jurisdictions where the Sponsor conducts business, such as the United States, require pharmaceutical companies to disclose information on compensation, gifts, or other remuneration provided to physicians and other health care professionals. The Sponsor may report information about remuneration provided as required. Once reported, such information may be publicly accessible, and your Personal Information may be required to be disclosed. Under this Privacy Policy, your Personal Information can be disclosed for this purpose and may be made public.

The Sponsor and third parties with whom the Sponsor has contracted to provide services to the Sponsor may also collect information from you through browser navigational tools, cookies, pixel tags, and other similar technologies. This may include: i. Browser Navigational Tools. We and our service providers may collect and use certain technology data, such as your computer type (Windows or Macintosh), screen resolution, Operating System (“OS”) version, Internet browser, and Internet browser version. This type of information is collected by many browsers and can be used to help optimize your experience on our website. ii. Cookies. We and our service providers may use “cookies” on our websites. A cookie is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences. There are two principal types of cookies: i. “Session” cookies are temporary bits of information that are used to improve website navigation, block website visitors from providing information where inappropriate, and collect aggregate statistical information on a website. These cookies are erased once you exit your web browser or otherwise turn off your computer. ii. “Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer so that we can, for example, retrieve information you have previously provided (such as passwords); better determine what areas of the website you find most valuable; and customize the website based on your preferences on an ongoing basis. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. To learn more about cookies, please visit http://www.allaboutcookies.org/. iii. Pixel Tags. We and our service providers may also use so-called “pixel tags,” “web beacons,” “clear GIFs,” or similar technologies (collectively, “Pixel Tags”) in connection with some website pages and HTML-formatted email messages to, among other things: track the online activity of website users and email recipients (including activity on other websites); determine the success of marketing campaigns; and compile aggregate statistics about website usage and response rates. iv. Other Sources. The Sponsor also may collect information (such as indications of your interests, your geographic location, and other demographic information) that you or others provide, and we also may aggregate this information and/or other information in our possession in a manner such that the end-product does not personally identify you or any other individual and so is not Personal Information. For example, we might aggregate information to calculate the percentage of our users who have a particular telephone area code, or to better understand certain medical usage patterns. Such aggregate information is not considered Personal Information for purposes of this Privacy Policy. As noted above, we and our service providers may use tracking technologies, such as cookies and Pixel Tags, to improve the usefulness and value to you of our website, as well as to gauge the success of marketing initiatives and to improve our marketing campaigns, by tracking your online visits to our websites and other websites not operated by us. For example, we may use such technologies to remind you of the Sponsor products when you are browsing another website or may collect aggregate information about other websites you have browsed. We reserve the right to use information that is not Personal Information for any other purpose as well. For example, we may use aggregated non-personal health information to publish reports on particular topics. In some instances, we may combine non-personal information with Personal Information (such as embedding email addresses in cookies). If we do combine any non-personal information with Personal Information, the combined information will be treated by us as Personal Information for so long as it is so combined. IP Addresses. Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (“ISP”). This number may be identified and logged automatically in our server log files whenever users visit the website, along with the time(s) of such visit(s) and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many websites. We may use IP addresses for purposes such as calculating website usage levels, helping diagnose server problems, ensuring appropriate access rights by authorized users, facilitating website security, and administering the website.

Your Personal Information is stored in secured locations and/or on servers, including in locations and servers located in Mississauga, Ontario, Woodcliff Lake and Totowa, New Jersey, as well as Research Triangle Park, North Carolina, or at the locations of our service providers or U.S. affiliates.

The Sponsor retains your Personal Information only for as long as is necessary in order to fulfill the purposes identified within this Privacy Policy, for as long as may be required to comply with applicable laws, or as required under the Sponsor’s record retention policies.

To help protect the confidentiality and security of your Personal Information, the Sponsor employs physical, administrative, and technological safeguards appropriate to the sensitivity of your Personal Information. If your Personal Information is sent to a third party for processing, we seek to make sure, through our contracts with such third parties, that all of your Personal Information is to be kept secure. Personal Information may only be accessed by persons within our organization, or our third-party service providers, who require such access to carry out the purposes identified to you or permitted or required by law. We also operate secure data networks protected by industry-standard firewall and password protection systems. We try to keep your Personal Information as accurate, complete, and up-to-date as is necessary to fulfill the purposes identified in this Privacy Policy. However, we do not routinely update your Personal Information. If any Personal Information you have provided to us has changed, please contact us for the purposes of updating it.

Upon your written request, and subject to certain exceptions, the Sponsor will give you access to the Personal Information we hold about you. Access requests should be sent to the Sponsor's Privacy Officer using the contact information outlined below.

If access to your Personal Information is denied, the Sponsor will notify you in writing, give reasons for the denial, and inform you of the recourses open to you. If access is granted, the Sponsor will give you a reasonable opportunity to review your Personal Information. Your Personal Information will be provided to you in an understandable form within a reasonable time, generally within 30 days. The Sponsor may extend such 30-day period by up to an additional 30 days in certain circumstances, including in cases where meeting the time limit would unreasonably interfere with the activities of the Sponsor or the time required to undertake any consultations necessary to respond to your request would make the time limit impracticable to meet. You will be able to challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.

The Sponsor does not typically collect Personal Information from children. If a child has already provided us with Personal Information, his or her parent or guardian may contact us for the purpose of deleting this information.

Our websites may contain links to other third-party websites. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any such third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from our websites to other websites, or references to products, services, or publications other than those of the Sponsor, do not imply the endorsement or approval of such websites, products, services, or publications by the Sponsor.

The Sponsor has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For more information on the Sponsor's privacy practices, please contact our Privacy Officer at 905-361-7130 or by email.

The Sponsor reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will make such revised policy and changes available on our website. However, the Sponsor will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use, or disclose your Personal Information for purposes other than those for which your consent has been previously obtained, unless otherwise required or permitted by law. Your continued access to and/or use of our website after any such changes constitutes your acceptance of, and agreement to be legally bound by, this Privacy Policy, as revised. Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it.

Date last revised: December 4, 2015