Privacy Statement

We at LEO Pharma Inc. (including our affiliates and related companies) (collectively, LEO Pharma Inc. or “we”) understand the importance of keeping your Personal Information private. We have developed the present Privacy Statement to explain the measures we take to ensure the privacy, security and accuracy of your Personal Information and complying with all applicable privacy laws.

We have also appointed a Privacy Compliance Officer to respond to any inquiries you may have concerning this Privacy Statement or more generally about our collection, use, or disclosure (“processing”) of your Personal Information. Our Privacy Compliance Officer can be reached at:

3389 Steeles Ave. E., Suite 110

Toronto, ON

M2H 3S8

Email: privacy.ca@leo-pharma.com

 

This Privacy Statement explains the types of personal information we process when you visit our website(s), use or our apps, or otherwise communicate with us through a number of different channels, such as, surveys you complete for LEO, and personal information provided during marketing, medical or educational events (collectively, “the Services”), including interactions with patient users, health care professionals, health care organizations, agencies/third parties and the general public. This Statement explains how we collect, why we process, and the third parties to whom we disclose your Personal Information.

 

• What is Personal Information?
• The types of Personal Information Collected, and how we may collect it
• The purposes for which we collect and How We Use Personal Information
• Sharing Personal Information with third parties
• The Internet technologies we may use to collect and process your Personal Information (Cookies and Website Technologies)
• Retention of Personal Information
• Protection of Personal Information and the locations in which it may be stored or processed
• How to access, correct or update your Personal Information or exercise any other data subject right (Access Correction and Other Data Subject Rights)
• How to Inquire About or Exercise Your Data Subject Rights
• The Roles and Responsibilities of the Members of our Team in Processing Your Personal Information

 

By visiting our sites, downloading or using our apps, or communicating with us any means or participating in any events/programs, you consent to the collection, use and disclosure of your Personal Information as set out in this Privacy Statement, and to our Terms of Use, which should be read.

 

You may generally withdraw your consent to our use or disclosure of your Personal Information at any time, subject to legal and contractual restrictions; however, without such consent, we may be unable to provide you with certain services or features. 

 

This Privacy Statement may be updated from time to time, to incorporate new products, services, features, technologies or legal requirements. Your continued use of the Services following the posting of an updated Statement shall be deemed to be conclusive acceptance of the modified Privacy Statement.  Accordingly, you should check this Privacy Statement periodically for updates.  To aid in detecting recent revisions, the latest revision date is located at the beginning of the policy.

 

Other sites to which we provide links may be governed by different privacy policies. LEO Pharma Inc. does not assume the responsibility for the information practices of these other websites, and we strongly encourage all Web visitors to review privacy statements and policies of all externally linked sites.  Note also that when interacting with LEO Pharma Inc. through a social media platform, such interactions will be governed by the terms of use and privacy policy for that platform.

 

Headquartered in Denmark, LEO Pharma Inc. is multinational company with offices and facilities around the globe.  Accordingly, your data may be transferred to a database within or outside your country of domicile, where it will be subject to the laws in the jurisdiction in which it is stored or processed, which may offer different protection than the laws in Canada.

 

• What is Personal Information?

 

For the purposes of this Privacy Statement, Personal information is any information about an identifiable individual, including any information that, when combined with other available information, could be used to identify you as an individual, except as otherwise excluded by law.  For example, Personal Information includes information such as your name, address, email address, and telephone number.  However, information relating to a corporation or business is not personal information.  Also excluded is business contact information, such as the name, professional title and business contact details of an individual, where collected, used and disclosed solely for the purpose of communicating with the individual in relation to their employment, business or profession.

 

In addition, Personal Information does not include information that does not identify you and cannot be associated with you as an identifiable person, such as aggregated information (like the total number of users visiting our site).

 

• Personal Information Collected

 

Directly Collected Information

 

You may browse the LEO Pharma Inc. website without providing any personal data, however, certain features require that you provide us with additional information about, you such as when registering for one of our programs or signing up for our mailing list. In such cases, we may ask you to provide us with certain Personal Information (such as your name, address, telephone number or e-mail address, and treatment area of interest).  In other cases, you may be requested to provide more detailed health information, such as when communicating about a question regarding a drug safety issue

 

Except as otherwise noted in this Privacy Statement, or as may be required or permitted by law, LEO Pharma Inc. will generally collect Personal Information directly from you.  Personal Information such as your name, address, telephone number, email address and other information, such as your resumé or other employment-related information, is generally only collected if you choose to provide it. If you do not want your Personal Information collected, do not provide this information to us.

 

In limited cases, we may receive from health care professionals personal information respecting patients that have experienced adverse reactions to our products and treatments, although we instruct health care professionals to report such results using only a patients’ initials.

 

Automatically Collected Information

 

In addition, as further detailed below (see Cookies and Website Technologies) our servers automatically collect certain information about visits to our website such as, but not limited to, the Internet browser you are using, the type of computer operating system you are using and the domain name or IP address from which you are linked to this website.

 

• How We Use Personal Information

 

Your Personal Information is generally used to provide the features and services available through our website and apps, to meet your ongoing needs and to better understand the users of our site and apps and the patients that use our treatments.

 

Among other things, LEO Pharma Inc. uses Personal Information for the following purposes and related purposes:

 

1. with your consent, to communicate with you, by email, text message or postal mail in order to provide you with information that you have requested and/or that we believe to be of interest to you, such as invitations to learning events;
2. communicate with you regarding any services you may receive, or any inquiries, concerns, requests or queries you may submit, including by telephone, fax and/or on any social media services that we may monitor or on which we maintain an account or page;
3. to communicate with you as appropriate regarding any changes to this Privacy Statement or any of our services;
4. to receive and process requests for donations to charitable and non-profit organizations, or for grants to support educational programs, activities or materials;
5. with your consent, or as permitted by law, to communicate with you regarding surveys with respect to our products and services;
6. to provide services to you generally;
7. to understand and analyze the interests, needs and preferences of our users, in order to improve our products and services;
8. to better understand the way our websites and/or apps are accessed and used, in order to optimize usability and utility;
9. to research, develop, enhance, market and/or provide products and services for our users and potential users;
10. where applicable, to process pharmacovigilance (adverse event and other experience) information, and to report (with limited identifiers) to Health Canada and other Health Authorities; more information about LEO Pharma Pharmacovigilance Notice of Personal Data Processing can be found at https://www.leo-pharma.com/contact/personal-data-processing
11. where you have applied for employment with LEO Pharma Inc., we will use the information that you provide for the purposes of evaluating and processing your application, and will retain your Personal Information for present or future consideration;
12. to detect and prevent abuse of our site and services, including with respect to fraud and other illegal activities;
13. to comply with applicable legislation and regulatory requirements; and
14. for investigation and law enforcement purposes.

 

Except as required or permitted by law, LEO Pharma Inc. will not use your Personal Information for any unrelated purpose without your further consent.

 

• Sharing Personal Information

 

From time to time, we may share your Personal Information with third party service providers that we have engaged to perform services on our behalf, based on our instructions, such as companies providing web hosting services, marketing agencies or health care professionals that we have engaged to provide support to patients using our treatments. We will limit our disclosure of your Personal Information to such third parties to that which is reasonably necessary for the purpose or service for which the service provider has been engaged.  We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, including limiting such providers to using your Personal Information solely to provide LEO Pharma Inc. with the specific service for which those providers were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us at the addresses and phone numbers set out under Contact Us.

 

From time to time we may disclose to third parties aggregated or de-identified data, which does not contain Personal Information or other information regarding identifiable individuals.

 

LEO Pharma Inc. may share or transfer your Personal Information where reasonably required in the context of a sale, merger, reorganization or amalgamation of all or part of our business or the insurance of securitization of our assets.  In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is completed, assignees or successors of our business or assets may use and disclose your Personal Information, as obtained from LEO Pharma Inc. only for the purposes set out this Privacy Statement, unless your further consent is obtained.

 

We may also share your Personal Information with third parties as required or permitted by law, such as:

 

• to government bodies and law enforcement agencies, pursuant to warrant, order or statutory requirement;
• in connection with any legal proceedings or prospective legal proceedings involving LEO Pharma Inc.;
• to otherwise establish, exercise or defend our legal rights (including providing information to third parties for the purposes of fraud prevention), or those of our users, as permitted by law

 

We do not otherwise release individual information about you or your use of our site, including your email address, to any third party. We do not sell or rent to third parties your email address or any other Personal Information, unless your additional consent to do so is obtained.

 

LEO Pharma Inc. will take reasonable measures to ensure that the Personal Information we collect is accurate and complete; however, we necessarily rely upon the information submitted to us by our users. In order to ensure that our records are as complete and accurate as possible, you are responsible for informing us of any relevant changes to your Personal Information, such as a change of name or a change of address or other contact details.

 

• Cookies and Website Technologies

 

When you visit our websites or use our apps, we may use certain automated tools to provide you with a more personalized browsing experience, better understand your needs, provide you with content that is most relevant to you and monitor trends respecting the usage of our site and apps.

 

In general, you can visit our public website without telling us who you are or submitting any personal information. However, through log files and other technologies, we collect the IP (Internet protocol) addresses of all visitors to our websites and other related information such as page requests, browser type, operating system and average time spent on our websites. We collect similar information respecting the usage of our apps. We use this information to help us understand user activity on our websites, to provide you with content appropriate for your region, and to monitor and improve our websites.

 

Cookies: Our websites use a technology called "cookies". A cookie is a small text file stored on your device that identifies your browser/device/IP address – but not you as an individual – to our computers each time you visit one of our websites.  More information about cookies can be found at https://en.wikipedia.org/wiki/HTTP_cookie

 

We use cookies on the pages on our websites where you are prompted to log in or that are customizable. If you have registered with our websites, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to provide personalized services, and (3) will provide us and our service providers with information that we will use to personalize our websites in accordance with your preferences and interests. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies (these controls are typically found in the privacy settings for your browser). You do not need to enable cookies to visit our website; however, if you decide not to accept cookies, you may not be able to take advantage of all of the features of that site.

 

Tracer Tags & Web Beacons: Our websites may also use a technology called "tracer tags" or “Web Beacons”. A web beacon https://en.wikipedia.org/wiki/Web_beacon  is a small transparent graphic image that allows us to record simple user actions related to our websites and to email communications received from us, to help us determine the usage and effectiveness of our site and communications.  These “images” are automatically loaded to your browser/device when you visit the website or open an html format email message from us, thereby letting us know if a certain page was visited or an email message was opened. This technology allows us to understand which pages you visit on our websites. These tracer tags are used to help us optimize and tailor our websites for you and future visitors.

 

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the websites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the convenience of the websites. For more information or to opt-out, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.

 

• Retention

 

LEO Pharma Inc. will only retain Personal Information to the extent necessary for the purposes identified in this Privacy Statement, or to which you might otherwise consent, after which your Personal Information will be securely destroyed or irreversibly erased or de-identified. 

 

As noted below, you may request deletion of your Personal Information in some circumstances.  Note that, notwithstanding such a request, in some cases, LEO Pharma Inc. may still retain some of your Personal Information for a reasonable period of time for legal, administrative or compliance purposes.

 

• Protection of Personal Information

 

LEO Pharma Inc. has established appropriate technological, physical and contractual security measures designed to help protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, by using security safeguards appropriate to the sensitivity of the Personal Information in question.

 

Encryption is used whenever Personal Information is requested from you. Our systems are protected by firewalls; however, unencrypted, electronically transmitted information is not 100% secure. Therefore, we cannot guarantee the security of any information you transmit to us electronically or that you request us to transmit to you via public Internet.

 

• Access, Correction, and Other Data Subject’s Rights

 

Depending upon the jurisdiction where you live, you may benefit from some or all of the following rights: 

 

(a) Access: You have the right to request whether we hold Personal Information on you and to request a copy of such information. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal Personal Information about another person, or if we are legally prevented from disclosing such information. 

 

(b) Accuracy: We aim to keep your Personal Information accurate, current, and complete. We encourage you to contact us to let us know if any Personal Information is not accurate or changes, so that we can update your Personal Information.

 

(c) Withdrawal of Consent: If you have provided your consent to the processing of your Personal Information, you have the right to fully or partly withdraw your consent. To withdraw your consent please follow the opt-out links on any marketing message sent to you or contact us at privacy.ca@leo-pharma.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing. Withdrawal of consent to receive marketing communications will not affect the processing of Personal Information for the provision of our services.

 

(d) Cessation of Dissemination: You have the right to request that we cease disseminating your Personal Information if the dissemination is contrary to the law or a court order. 

 

You also have the right to request that we cease disseminating your Personal Information where the following conditions are met: 

• (i) the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected; 
• (ii) the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and
• (iii) the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.

 

(e) De-indexation: You have the right to request that we de-index any hyperlink attached to your name that provides access to information by a technological means if the dissemination is contrary to the law or a court order. 

You also have the right to request that we de-index a link providing access to your personal information where the following conditions are met: 

 

• (i) the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
• (ii) the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and
• (iii) the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.

 

(f) Re-indexation: You also have the right to request that we re-index a link providing access to information where the following conditions are met: 

 

• (i) a failure to do so causes you serious injury in relation to your right to have your reputation or privacy respected; ű
• (ii) the injury caused by a failure to re-index is greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and 
• (iii) the re-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury. 

 

(g) Mobility: You have the right to request that computerized Personal Information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such information. This right does not extend to information that was created or inferred from your Personal Information and we are under no obligation to communicate such information if doing so raises serious practical difficulties. 

 

(h) Complaints: If you believe that your Personal Information protection rights may have been violated, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy thought the courts.

 

Inquiring About or Exercising Your Rights

 

You may enquire about your Personal Information by contacting our PCO or making a request to view your Personal Information by contacting privacy.ca@leo-pharma.com.

 

We will generally respond to all access requests within 30 days of the receipt of all necessary information. In circumstances where we are not able to provide access, or if additional time is required to fulfill a request, we will advise you in writing.

 

We may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions.

 

In certain circumstances, such as where the request is excessive or unfounded, we may charge you an administration fee for access to your Personal Information. We may also charge for additional copies. We will advise you of any fees before proceeding with a request.

 

Roles and Responsibilities

 

Leo Pharma Inc. is responsible for communicating this Privacy Statement and ensuring that our employees fully comply with all its relevant aspects and the accompanying guidelines.
The business or infrastructure units that process Personal Information other than as required, are responsible for ensuring that these activities comply with this Statement. 

 

Our PCO is responsible for:

 

• (a) helping develop our Personal Information protection strategy;
• (b) developing and maintaining this Statement, accompanying guidelines and any other policy or procedure related to Personal Information and ensuring they comply with applicable law; and
• (c) serving as the official liaison with the federal and provincial commissioners.