This Privacy Policy applies to a research-based pharmaceutical
company, a member of a group of research-based pharmaceutical companies
and the Sponsor of this program or website (the “Company”, “Sponsor”,
“it”) in respect of its processing of personal information or personal
health information (collectively “personal information”) in connection
with its activities in Canada.
The purpose of this Privacy Policy is to inform healthcare providers,
patients, participants in clinical studies, customers, and other
individuals the Company deals with ("you" or "your") how it collects,
uses, discloses, and protects your personal Information.
Personal information is information about an identifiable individual,
as more particularly defined and limited by applicable privacy laws.
This Privacy Policy applies to the collection, use and disclosure of
personal information in Canada. This Privacy Policy does not apply to
personal information about the Company’s employees nor to information
that is not personal information.
In carrying on its business, the Company collects various types of
personal information including personal information about healthcare
providers (including physicians, pharmacists, and other healthcare
workers), patients, participants in clinical studies, and customers.
Personal Information that it collects may include:
- names, titles, addresses, telephone numbers, email addresses and other contact information;
- information that its sales representatives may collect during visits
with healthcare providers, such as: areas of practice or
specializations;
- qualifications and professional credentials;
publications; questions, comments or opinions about its products; and
other information relevant to establishing and maintaining its
relationships with healthcare providers;
- the names and contact information of patients who use the Company’s products and their healthcare providers;
- information, including personal health information and medical
histories, of patients participating in the Company’s patient support
programs, patient assistance or similar programs and services. The
Company may administer and manage these programs directly or may use
third-party service providers to administer these programs and services
on its behalf. It may receive identifiable, de-identified or coded
information when administering or managing these programs, either
directly or through its third-party service providers;
- the necessary information to make adverse drug reaction reports to
Health Canada, which information is generally recorded using an initial
for a patient rather than the patient’s name;
- names and contact information of healthcare providers involved in
clinical trials and information relating to their professional
qualifications and experience as required by regulation;
- information (including personal health information and medical
histories) about patients participating in clinical trials or other
studies; and
- other information, with your consent or as permitted or required by law.
The Company generally uses personal information for the following purposes:
-
establishing, maintaining, and managing relationships with healthcare
providers, customers and other individuals that it deals with in the
course of its business;
-
conducting and evaluating clinical studies and related research and
development, and otherwise developing and improving its products;
-
providing advice, assistance and recommendations to healthcare providers
with respect to its products to meet healthcare provider needs;
-
providing healthcare providers with clinical evaluation packages;
-
establishing and sponsoring educational or other programs and
administering health condition awareness/management or similar programs;
-
responding to feedback, questions, comments, requests, inquiries,
complaints, or reports of adverse event reports about its products or
services;
-
generating adverse drug reaction reports or other reports required by regulatory bodies;
-
notifying individuals about product-related matters, including product recalls;
-
marketing its products and services;
-
administering contests, promotions, surveys, quizzes or polls;
-
maintaining business records for reasonable periods and generally
managing and administering its business including defending and bringing
legal actions;
- meeting legal, regulatory, insurance, security, and processing requirements; and
- otherwise with consent or as permitted or required by law.
The Company discloses personal information in the circumstances described below:
- to regulatory agencies as required by law, or in order to meet our regulatory requirements and legitimate business purposes; and
-
otherwise with consent or as permitted or required by law.
Personal information may be used by the Company and disclosed to parties
connected with a proposed or actual financing, securitization,
insuring, sale, assignment or other disposal of all or part of the
Company or its business or assets, for the purposes of evaluating and/or
performing the proposed transaction. Assignees or successors of the
Company or its business or assets may use and disclose your personal
information for similar purposes as those described in this Privacy
Policy.
The Company may transfer personal information to outside agents or
service providers (including its affiliates acting in this capacity) for
reasons such as data processing, data warehousing, administrative
services, conducting programs or services, and otherwise collecting,
using, disclosing, storing or processing personal information on its
behalf for the purposes described in this Privacy Policy. The Company
uses reasonable contractual or other means to require third parties to
commit to protecting personal information to a level comparable to that
provided by us. Some of these service providers may be located outside
of Canada and your personal information may be collected, used,
disclosed, stored and processed in these jurisdictions for the purposes
described in this Privacy Policy. While your personal information is
located outside Canada it may also be subject to the laws of the
jurisdiction in which it is retained, including laws that may require
disclosure of personal information to foreign government authorities.
IP Addresses and Server Logs
The nature of the internet is such that it passively and
automatically collects certain information about a user's traffic
patterns linked to their Internet Protocol (IP) addresses. These are
unique Internet "addresses" assigned to all web users by their Internet
Service Providers (ISP). IP addresses are automatically logged by web
servers. While the IP address does not generally identify an individual
on its face, it may, with the cooperation of the ISP, be used to locate
and identify an individual using the internet.
The Company’s servers automatically log information about visits to its
website(s) in the normal course of establishing and maintaining web
connections. Server logs record statistical information, such as
visitors' IP addresses, type of operating systems, time and duration of
visit, web pages requested, and identify categories of visitors by items
such as domains and browser types. These statistics are reported in
aggregate form to the Company and are used to improve its website and
ensure that it provides the optimal web experience for visitors.
The Company does not link server log information to any other data in a
way that would enable it to identify individual visitors. However, it
may review server logs for security purposes, for example, to detect
intrusions into its network.
Cookies and Other Tracking Technologies
As with many other websites, the Company’s website(s) makes use of
session and permanent “cookie” technology. Cookies are small text files
that contain a unique identification number that is automatically
deposited on a visitor’s computer. The Company uses aggregate
information, which does not identify individuals, to monitor customer
traffic patterns to the website and particular pages, as well as site
usage, in order to help improve the design and layout of the content. In
addition, the Company uses other tracking technologies to better
understand its communication channels and your experience with the
Company.
The Company may also collect information about how you use the website
using cookies (and other similar technologies), as part of improving the
content and functionality of any of its websites. For more information
about the use of cookies please see the cookie notice on the webpage.
The Company does not respond to Do-Not-Track Signals.
The Company does not cross-reference the information automatically
collected through “cookies” with any type of personal information that
is voluntarily offered on or through its websites.
The use of cookie technology is common on the Internet, and many
internet browsers are initially configured to accept cookies
automatically. If you would prefer not to accept cookies, you can set
your internet browser to notify you when your computer is receiving a
cookie or to refuse cookies automatically. However, if you refuse to
accept cookies, this may limit your use of the Company’s website(s).
Other websites to which the Company’s website(s) or programs provide
links to are governed by different privacy policies. The Company does
not assume responsibility for the content or information practices of
these other websites, and strongly encourages all web visitors to review
the privacy statements and policies of all externally linked sites.
Consent to the collection, use and disclosure of personal information
may be given in various ways. Consent can be express (for example,
orally, electronically or on a form you may sign describing the intended
uses and disclosures of personal information) or implied (for example,
when you provide personal information necessary for a service you have
requested). You may provide your consent in some circumstances where
notice has been provided to you about our intentions with respect to
your personal information and you have not withdrawn your consent for an
identified purpose, such as by using an “opt-out” option provided, if
any. The form of the consent sought by the Company, including whether
this consent is express or implied, may vary depending upon the
circumstances and the type of personal information. In determining the
form of consent to use, we will take into account the sensitivity of the
personal information and the reasonable expectations of the individual.
Generally, by providing your personal information, the Company will
assume that you consent to the collection, use and disclosure of such
personal information for the purposes identified or described in this
Privacy Policy, as applicable, or otherwise at the time of collection.
If an individual is not capable of consenting to the collection, use or
disclosure of his or her own personal information, consent must be
obtained from the person who is legally entitled to consent on behalf of
the individual.
You may withdraw your consent to the collection, use and disclosure of
your personal information at any time, subject to contractual and legal
restrictions and reasonable notice. Note that if you withdraw your
consent to certain uses of your personal information, the Company may no
longer be able to provide certain of its products or services. You will
be informed of the implications of withdrawing consent. In certain
circumstances, you may not be permitted to withdraw consent to certain
necessary uses and disclosures of the personal information for which
your consent was originally collected.
The Company collects, uses and discloses your personal information with
your consent, except as permitted or required by law. It may be required
or permitted under statute or regulation to collect, use or disclose
personal information without your consent, for example to comply with a
court order, to comply with local or federal regulations or a legally
permitted inquiry by a government agency, or to collect a debt owed to
it.
The Company implements reasonable security safeguards to protect
personal information against loss or theft, as well as unauthorized
access, disclosure, copying, use or modification, regardless of the
format in which the personal information is held.
The methods of protection include:- physical measures (e.g., locked filing cabinets and restricted access to desks);
-
organizational measures (e.g., security clearances and limiting access on a “need to know” basis); and
- technological measures (e.g., the use of passwords, gating and encryption).
Authorized Company employees, agents and mandataries have access to your
personal information as required to fulfill their responsibilities to
the Company.
The Company maintains a file of personal information for individuals for
the purposes described in this Privacy Policy, which will be accessible
at the address provided in the Contact Information section below. If
you wish to request access to or correction of your personal information
in the Company’s custody or control, you may email the Company’s
Privacy Officer at the email below. Your right to access or correct your
personal information is subject to applicable legal restrictions. The
Company may take reasonable steps to verify your identity before
granting access or making corrections. For more information about the
collection, use and disclosure of personal information, including about
personal information that is collected, used, disclosed, stored or
processed outside of Canada, you may contact the Company using the
contact information listed below.
The Privacy Policy is effective as of the Effective Date above. This
Privacy Policy may be revised from time to time. For the most current
Privacy Policy, please visit the Company’s website. You are encouraged
to review this Privacy Policy frequently to obtain the current version.
Your continued provision of personal information or use of the Company’s
services following any changes to this Privacy Policy constitutes your
acceptance of any such changes.
Accountability for compliance with privacy policies and procedures rests
with the Company’s Privacy Officer, even though other individuals
within the Company may be responsible for the day-to-day collection and
processing of personal information. In addition, the Privacy Officer
may, from time to time, designate one or more other individuals within
the Company to act on his or her behalf, including representatives from
all areas of the business. Contact information for the Company’s Privacy
Officer can be found here.
