Last Updated: March 2017
This website is provided by one of Canada’s leading pharmaceutical research-based companies (“the Company, “we”, “us” or “our”).
The Company recognizes our responsibility to protect personal information in our custody or control. “Personal information” is information about an identifiable individual, such as your name, address, email address, phone number, health information, and comments or inquires you have made about our products or services when such comments or inquiries are linked to you.
This Privacy Statement applies to individuals who this website (“you” or “your”), and explains how we collect, use, disclose and protect your personal information.
Personal Information Collection
Subject to what is set out in this Statement, the Company and its agents and representatives do not collect personal information about you except when you provide it to us voluntarily or in other circumstances with your consent or as permitted or required by law.
Active Information Collection
Our websites may actively collect personal information from visitors both by asking you specific questions and by permitting you to communicate directly with us via email and/or feedback forms, and/or chat rooms. We may also collect personal information if you interact with the website or the Company via social media. Also, although you are not required to register to access the website, you may be asked to provide certain personal information when you visit certain sections of our website.
Passive Information Collection
Our web sites may use and combine such passively collected anonymous information to provide better service to site visitors, customize the sites based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the sites for your use. Such information is not combined with personal information actively collected on our web sites unless you have consented.
The following is a description of cookies and other passive tracking methods.
A “cookie” is a bit of information that a web site sends to your web browser that helps the site remember information about you and your preferences.
“Session” cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate and collect aggregate statistical information on the site. They are erased once you exit your web browser or otherwise turn off your computer.
“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 for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the web site visitors find most valuable, and customizing the web site based on your preferences on an ongoing basis.
IP Addresses and Tags
A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider. In most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.
“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the web site server information such as the IP address and browser type related to the visitor’s computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted
The Company collects personal information for a variety of purposes relating to the operation of our business and the delivery of services to you, including to:
- provide our products and services and generally manage and administer our business including maintaining business records for reasonable periods and defending and bringing legal actions;
- develop and improve our products;
- provide you with health and product-related information;
- reply to your requests, inquiries and comments;
- receive and assess product inquiries, reports of adverse events, and product complaints;
- meet legal, regulatory, insurance, security, ethical and processing requirements such as adverse event and clinical reporting to Health Canada and regulatory bodies;
- offer and administer contests, promotions, surveys and web sites including social media;
- ensure the security and integrity of our web sites and operations.
“Navigational data” (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, for market research purposes, and to communicate information to visitors.
We may also use your personal information for other purposes with your consent or as permitted or required by law.
Use of Service Providers
The Company may disclose your personal information in the following circumstances:
We may disclose personal information when required in order to meet legal, regulatory, industry self-regulatory, insurance, audit, security or ethical requirements, including obligations to health and drug regulatory and self-regulatory bodies, physicians, hospitals, or other health care facilities.
We also may disclose your personal information to third parties, located in Canada and/or any other country, where required or permitted by applicable laws, court orders, or government regulations (including as required by Canadian and foreign laws applicable to the Company or our agents and service providers).
We may also disclose your personal information with your consent.
In addition, we may disclose aggregated information which does not allow you to be personally identified to third parties.
Consent to the collection, use and disclosure of your personal information may be given in various ways. Consent can be express (express consent may be oral, in writing or electronic), implied (such as when you provide your name and address in order for us to send you products or information you have requested) and may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). 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.
There are instances where we may be permitted or required by law to collect, use or disclose your personal information without your consent including, 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 us.
We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information. The Company will take appropriate steps to ensure that personal information about you is protected from loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
Access, Correction and Contacting Us
You may contact us as described below in order to:
- request to withdraw your consent to our retention, use or disclosure of your personal information; and/or
- request access to or correction of your personal information.
Requests regarding items 3 and 4 above must be made in writing. We will take reasonable steps to verify your identity before granting access or making corrections.
You may contact us by writing to us at the following address: Chief Privacy Officer, 19 Green Belt Drive Toronto, Ontario M3C 1L9; or by faxing us at 416-449-2658, attention Chief Privacy Officer.