Tolmar respects your privacy and understands that health is a very personal and private subject.

Before using Tolmar Canada's sites, please read this privacy policy carefully.

LAST UPDATE OF THIS PRIVACY POLICY – October 1, 2021

1. Scope

1.1  This Privacy Policy applies to the practices and operations of Tolmar Pharmaceuticals Canada, Inc. (“Tolmar Canada”, “we”, “our” or “us”) in Canada regarding the collection, use, and disclosure of Personal Information (as defined below) of patients, customers - including individuals who request information about our products and services, health care professionals, online visitors or members of our websites, online resources, mobile devices, applications. This Policy describes (i) the types of Personal Information collected, (ii) the manner of collection and (iii) the purposes of the collection and of its disclosure and/or transfer. It also describes (iv) the measures we take to protect the security of Personal Information and (v) your rights regarding Personal Information. This Policy does not apply to our employees acting as such or to information which does not qualify as Personal Information.

1.2  This Policy does not apply to the collection, use, and disclosure of Personal Information by third parties, where Tolmar Canada does not have any control over the collection of Personal Information or over their respective privacy practices.

1.3 There may be links from Tolmar Canada's sites to other web sites; note that this Privacy Policy applies only to Tolmar Canada's sites and not to web sites of other companies or organizations to which Tolmar Canada's sites may be linked. You must check any linked sites for the privacy policy that applies to that site and direct any related inquiries to the operator of the linked site. Links to third party websites are provided as a convenience and are for informational purposes only. Tolmar Canada does not endorse, and is not responsible for, these linked websites.

1.3  By “Personal Information” we mean any information collected, used by or on behalf of Tolmar Canada enabling it to directly or indirectly identify an individual. Personal Information may include but is not limited to the first name, last name, address, telephone number, date of birth, email address, Internet protocol (IP) address used to connect your computer to the Internet, and health-related information.

2. Consent

2.1  By providing and/or allowing your Personal Information to be provided to Tolmar Canada according to the practices described in section 3 below, you consent to the terms and conditions of the present Privacy Policy and notably to the collection, use, and disclosure of your personal information by Tolmar Canada.

2.12 If you do not consent, please do not provide your Personal Information or, where applicable, exercise the opt-in or opt-out options offered. Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information or you may withdraw your consent to our further collection, use and disclosure of your personal information by sending a written request to Tolmar Canada’s Privacy Officer at the address below.

3. Collection of Personal Information

3.1 Tolmar Canada may collect the following types of Personal Information:

• name, postal address, email address, telephone number, date of birth;
• Internet protocol (IP) address used to connect your computer to the Internet;
• information relating to professional skills, credentials, experiences and interests;
• health information in relation to one of our products, services, clinical trials or research;
• health information to comply with our pharmacovigilance obligations or legal requirements as per applicable laws and regulations; and

3.2  Personal Information may be collected in the following manner:

3.2.1 information provided by you:

• when contacting us or communicating with us via telephone, by mail, email or facsimile regarding one of our products, services, websites or online initiatives;
• in your capacity as a healthcare professional;
• online while visiting one of our websites or online initiatives;
• online via one of our online websites or online initiatives in data forms and/or field queries;
• when using one of our electronic or mobile devices applications or tools;
• when participating in a clinical trial or research; and
• when submitting your resume to us for employment purposes;

3.2.2  information provided by one of your healthcare professionals or member of your entourage regarding an adverse experience in relation to one of our products, further to your consent;

3.2.3 information derived from public sources or provided by service providers which information services  are governed by separate rules of protection of Personal Information;

3.2.4 Web Logs
Tolmar Canada websites may also automatically collect and store web log information relating to your computer and your visit, such as the name of the domain and host from which you access the Internet; the Internet address of the website from which you linked to a Tolmar Canada website; the date and time you accessed a Tolmar Canada website, how long you spent and which pages you visited; your computer's operating system and browser software; and your Internet protocol (IP) address. An IP address is a number assigned to your computer by your Internet Service Provider so you can access the Internet. This number may change each time you connect to the internet (“dynamic IP address”) or it may remain constant (“static IP address”). If you have an IP address, it is possible that this address could be used in combination with other information to identify you.

3.2.5 Google Analytics and its advertising features
Some of our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics and its advertising features use cookies to analyze use patterns and may collect information about your use of the website, including your IP address. More information on Google Analytics can be found here and more information about the use of cookies by the advertising features of Google Analytics can be found  here.

Among the features of Google Analytics Advertising Features, we have implemented the following features:

• Remarketing with Google Analytics to create audiences of visitors of our websites and share them with our ads accounts and offer them, as part of our campaigns on the Google Search Network and Google Display Network, relevant ads focused on the actions they took during their visits.
• Google Analytics Demographics and Interest Reporting to a) determine the distribution of the audience of our websites by age, gender and interests, b) to improve the targeting of our advertising expenses, c) to create segments for our reports, and d) to create remarketing lists. 
• Integrated services that require Google Analytics to collect data for advertising purposes, including the data collect by advertising cookies and device identifiers to maximize the benefits of these products by combining them and then sharing the data in each associated account.

We refer you to section 3.2.4 of this Policy regarding how we and our advertisers use cookies (cookies of our websites and cookies of third parties), including cookies from Google Analytics, and how you can opt out Google Analytics Advertising Features. We encourage you to use the Google Analytics Web Deactivation Add-on for this purpose, which you can download here:. 

3.3 As the case may be, the collection of Personal Information may be governed by a disclosure document requiring your acceptance.

3.4 In the case of a clinical trial or research the collection of Personal Information will always require an explicit consent in compliance with the applicable laws, regulations and guidelines and the collection, use and disclosure of such Personal Information will be governed by the terms provided for in the consent.

4. Purposes

4.1 Personal Information may be collected and used for the following purposes:

• to respond to your inquiries on our products or services and to provide you with customer service further to your request;
• in your capacity as a health care professional, to provide you with relevant information and assistance on our products or services and to manage our customer relationships;
• for the management of clinical trials, research or disease management programs;
• occasionally, as permitted by applicable laws and regulations and if you have provided us with a prior consent to communicate with you (via phone, mail, email or online) about our products, services, promotional offers;
• for the registration or reservation in one of our websites or online resources;
• to grant you access to one of our mobile devices, applications or tools;
• to permit us to improve our products, services, websites, online resources, mobile devices, applications or tools;
• to allow us to enhance the quality of our services;
• to process any product complaints, including to allow us to comply with regulatory requirements and submit reports to Health Canada and/or other relevant regulators in relation to an adverse experience with one of our products and to notify you of a product recall, as may be required by the regulatory authority; and
• to allow us to assess your employment application.

4.2 Information may be consolidated and aggregated in an anonymous manner in order to generate statistics in relation to our products, services, websites, online resources, mobile devices, applications or tools or for reporting purposes to government authorities.

4.3 Any other collection and use of your Personal Information will be solely for the purposes disclosed to you at the time of collection, with your consent and as permitted or required by laws and regulations. Only the Personal Information necessary to fulfill the intended purposes is collected.

5. Information We Share

5.1 We do not disclose Personal Information except as described herein unless otherwise authorized and required by applicable law or relevant Court proceedings. Where Personal Information is disclosed, only the Personal Information necessary to fulfill the intended purposes is disclosed.

5.2  Personal Information about you will be accessible only to authorized employees of Tolmar Canada and/or of its affiliates who need to have access to the Personal Information in order to perform their duties in relation to the purposes.

5.3  Tolmar Canada may retain agents, consultants and/or suppliers (collectively “third-party service providers”) to assist and support its business and services. These third-party service providers may have access to Personal Information within the scope of the purposes if it is required for the performance of their services. When we transfer or provide access to Personal Information to third-party service providers, we contractually ensure that such providers provide Personal Information protection, including requiring that they respect this Privacy Policy and are responsible for the security of the Personal Information disclosed.

5.4  Your Personal Information may be consolidated, aggregated and rendered anonymous for internal research or reporting to governmental authorities purposes and disclosed to third parties as such (i.e. in an unidentifiable manner).

5.5  Some of the third parties, service providers, affiliates or related companies (including Tolmar Canada’s affiliate company, Tolmar Pharmaceuticals, Inc.) that may collect, use, store or process your information may be located outside of Canada, including in the United States. As a result, your personal information may be transferred, stored, and/or processed outside Canada in connection with the purposes described in this Privacy Policy. Contractual or other measures Tolmar Canada may use to protect your personal information are subject to the legal requirements of the foreign jurisdictions where your personal information may be transferred, stored, or processed (for example, lawful requirements to disclose personal information to government authorities in those countries).

5.6   We reserve the right to transfer any Personal Information we have about you in connection with the sale or transfer of all or a portion of our business or assets or rights relating thereto. In such cases, we will use our best efforts to obtain guarantees that your Personal Information will continue to be protected as per the applicable Canadian personal information and privacy laws and regulations.

6. Records Retention

Tolmar Canada will only retain Personal Information as long as needed to fulfill the relevant purposes. The Personal Information will be held primarily in an electronic database. The file containing your Personal Information will be made available to the authorized employees, third-party service providers of Tolmar Canada and/or its affiliates who need to access the information in connection with the purposes.

7. Security

We maintain appropriate administrative, technical and physical safeguards and use appropriate commercially reasonable efforts to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and all other unlawful forms of processing of the Personal Information in our possession.

8. Your Rights

8.1  You have certain rights to access and rectify your Personal Information.

8.2  If you wish to request access to, or correction of, your Personal Information that we have in our custody or control, please make your request in writing to our Privacy Officer at the address below. If the Personal Information collected is incorrect, inaccurate or outdated, we will correct such information within a reasonable period of time. We may need to verify your identity before searching for or providing you with Personal Information. In some circumstances, we may not provide access to your Personal Information, for example, if it contains the Personal Information of other persons, if it constitutes confidential commercial information, if it is protected by solicitor-client privilege, or if it is otherwise not properly the subject of an access request.

8.3  Tolmar Canada respects and observes the provisions set forth in the Personal Information Protection and Electronic Documents Act (the “Act”) and any other applicable Canadian federal or provincial legislation regulating the protection of personal information in the private sector. To the extent there is additional protection afforded to an individual pursuant to the Act or any such other applicable privacy legislation, and same is not set forth herein, Tolmar Canada agrees to take such measures to give full effect to such additional protection.

9. Contacting Us

If you have any questions, comments or concerns about this Privacy Policy, please contact our Privacy Officer at:

Tolmar Pharmaceuticals Canada, Inc.

Toronto Airport Corporate Centre

2425 Matheson Boulevard East, 8th Floor

Mississauga ON L4W 5K4

Or call 1-844-9TOLMAR (1-844-986-5627)

Tolmar Canada reserves the right to change this Privacy Policy at any time. We will always handle your personal information in accordance with the Privacy Policy in effect at the time it was collected. You can access the current version of this Privacy Policy online at www.tolmar.ca or by contacting our Privacy Officer.