PRIVACY POLICY

General

1. This Privacy Policy is designed to tell you about the practices of Lupin Pharma Canada Inc. (“Lupin Canada”, “we” or “us”) regarding the collection, use, and disclosure of Personal Information (as defined below) via the Flushing Out IBS Canada website and all of its related pages www.flushingoutibs.ca (the “Site”). Specifically, this policy describes (i) the types of Personal Information collected on this Site and the manner of collection, (ii) the use of that Personal Information, and (iii) its transfer and/or disclosure. It also describes the measures we take to protect the security of the Personal Information. In addition, we tell you how you can reach us to answer any questions you may have about our privacy practices. Please be sure to read this entire Privacy Policy before using this Site, or submitting Personal information

 

2. Except for Lupin Canada’s applicable legal requirements and duties detailed in the Terms of Use and for the Purposes detailed herein, Lupin Canada and its affiliates will not have access to any Personal Information. In addition, employees of Lupin Canada and of its affiliates and service providers who require it for the purposes of their duties will have access to aggregated or unidentifiable information for the Purposes outlined below.

 

3. Please check this Privacy Policy frequently for updates by checking the date of the “Last Updated” at the top of this Privacy Policy. We may change or update all or parts of this Privacy Policy at any time. Please check back from time to time so you are aware of any changes or updates to this Policy. The Privacy Policy which in each case shall apply to your Personal Information shall be the version posted as of the point that the applicable Personal Information was collected.

 

Collection, Use And Disclosure Of Your Personal Information

 

4. The Site is not intended to receive confidential information from you. Consequently, and except for personal data mentioned herein, any information, whatever its form – document, data, graphic, question, suggestion, concept, comment or other – that you send us via and in relation to the Site will not under any circumstances be deemed confidential.

 

5. We collect, use and disclose your Personal Information for the following purposes:

·       sending you, with your permission information related to IBS;

·       performance and improvement of the Site;

·       gathering data on the Site navigation;

·       to respond to your query via the “Contact Us” section;

·       for any additional purposes identified at the time of collection; and

·       as otherwise as permitted or required by applicable law (collectively the “Purposes”).

 

6. Generally stated, by “Personal Information” we mean any information about an identifiable natural person, as further defined in applicable privacy laws. Personal Information may include but is not limited to your name, address, telephone number, date of birth, and email address relating to the Site.

 

7. Except for any log files and cookies to the extent set out below, if you are simply visiting our Site, without sharing any information/query, we do not collect any of your Personal Information

 

Information We Share

 

8. We do not disclose Personal Information about our Site users visiting the Site, except as described herein, and as otherwise permitted or required by applicable law.

 

9. Third-party service providers: Lupin Canada has engaged third-party service providers to provide certain services and assist with the daily operations and maintenance of the Site, these services may include:

·       sending you, with your permission information related to IBS,

·       processing requests made by you on the Site via the “Contact us” section; logistics/technical and level support, and;

·       testing and validation, hosting, management of the Site (collectively the “Services”).

 

These third-party service providers may have access to Personal Information, solely for the purposes of providing these Services, as required. When we transfer or provide access to Personal Information to third party service providers, we contractually ensure that such providers provide a high level of Personal Information protection, including requiring that they respect this Privacy Policy and are responsible for the security of the Personal Information. They are not authorized by us to collect, use or disclose the Personal Information except as necessary to perform the Services on our behalf in relation to the Purposes as described herein, or to comply with legal requirements.

 

10. The collection, use, and disclosure of information contemplated in this Privacy Policy may involve a transfer of the information to jurisdictions located outside your country of residence that may not have equivalent laws and rules regarding personal information. The reasonable contractual measures we may take to protect Personal Information while processed or handled by these third parties are subject to applicable foreign legal requirements, for example lawful requirements to disclose Personal Information to government authorities in those countries.

 

11. 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. Should such a sale or transfer occur, we will request that the transferee use and disclose Personal Information you have provided through this Site in a manner that is consistent with this Privacy Policy.

 

12. The Site is not intended to solicit adverse experience for Lupin Canada products, Lupin Canada’s affiliates’ products or products of other companies. As a user of this Site, if you provide information about an adverse experience while using any of Lupin Canada’s products, we may use the information you provided to submit reports to Health Canada and/or other relevant regulators. We may be required to contact you and/or your health care professional for further information. You understand that in order to comply with the law, we may not be permitted to meet your request to amend or remove Personal Information you provided to us or a third party regarding an adverse experience while using any of Lupin Canada’s products.

 

13. Other than for the purpose of pharmacovigilance (adverse event) regulatory purposes, in rare situations Lupin Canada may be required by court order or other legal or regulatory process, or as otherwise required by law to divulge personally identifiable information (Personal Information) to law enforcement authorities, the courts, or regulatory authorities. Lupin Canada will cooperate in responding to such requests, in accordance with the regulatory or legal process, and will take appropriate measures to ensure that the requester understands the sensitive nature of any health-related personally identifiable information they receive.

 

Cookies And Logfiles

 

14. Information we collect automatically may include information, such as your IP address, domain name, web page, the length of time spent on the site and/or a page, and the pages accessed while visiting the Site, which, to the extent such information is identifiable with you, is Personal Information. We collect this Personal Information through “log files” and “cookies.” Log files are small text files that websites automatically create when a user visits a site. This information collected through log files is stored on the server on which the website is hosted. A cookie is a tool that enables us to track and target your preferences. They help us to learn, for example, how many new visitors the site is getting, and to identify site features in which you may have the greatest interest. Cookies and log files may enhance your online experience by saving your preferences while you are visiting a particular page. They thus help us to provide you better designed and personalized services. Like many companies we also aggregate the Personal Information we collect automatically. The cookie will be stored on your computer’s hard drive until you remove it. We may also use temporary or “session” cookies to help you use this Website. These temporary cookies will expire when you leave the Website.

 

15. If you want to stop using the cookie functionality of your browser, the “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember though, without cookies, you may not be able to take full advantage of all our Website features. Some of our business partners or the owners of websites that link to our website may also use cookies, however, we have no access to, or control over, these cookies and do not accept any responsibility for their practices.

 

Links To Other Websites

 

16. Occasionally we provide links to other third party websites for your convenience. These sites operate independently from this Site and are not under our control. These sites may have their own privacy practices, notices or policies in place, which we strongly suggest you review if you visit them. Without limitation, we are not responsible for the content of these sites, any products or services that may be offered through these sites or any other use of these sites, nor for any Personal Information processing and privacy practices associated with such sites.

Records Retention

 

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

Security

 

18. We maintain appropriate administrative, technical and physical safeguards 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. When you provide Personal Information online, we use encryption on the Internet which is industry standard for this type of information — Secure Socket Layer (SSL) technology — to help protect the information that you provide. This Internet encryption standard scrambles Personal Information as it travels from your computer to our server. You will know that you are in a secure area of our website when a lock icon appears on your screen that the “http” prefix of our URL address changes to “https.” The “s” represents “secure.”

 

Your Rights

 

19. You have certain rights to access and rectify your Personal Information contained in the file held about you, and in order to exercise this right, or if you have any questions, comments or concerns about this Privacy Policy, you may use the contact information provided below in How to Contact Us in order to contact us. If the Personal Information collected is incorrect, inaccurate or outdated, we will correct such information within a reasonable period of time.

 

20. We hereby agree to respect and observe the provisions set forth in Quebec Act respecting the protection of Personal Information in the Private Sector (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 you, pursuant to the Act or any such other applicable privacy legislation, and same is not set forth herein, we agree to take such measures to give full effect to such additional protection.

How to Contact Us

 

21. If you have any questions, comments or concerns about our privacy practices, including our practices and policies in relation to our use of service providers, or want to have access to and have your Personal Information corrected, please contact socialmedia@toctoccommunications.com

 

Terms of Use

This page describes the terms and conditions governing the use of this website (hereinafter the “Site”).

By visiting the Site you unconditionally undertake to comply with these terms and conditions.

As terms and conditions may be amended at any time, without prior notice, we advise you to consult them regularly.