Privacy policy

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.

Collecting 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.

Using Personal Information

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.

Disclosing Personal Information

The Company discloses personal information in the circumstances described below:

Applicable Law and Regulatory Requirements

  • 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.

Business Transactions

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.

Service Providers

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.

The Company’s website(s) and the Internet

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.

Your Consent

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.

Access and Correction

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.

Privacy Policy Changes

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.

Contact Information

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.