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Privacy policy

This Privacy Policy applies to the information that Norwell Consumer Healthcare Inc. (“we”, “our”, “us”) collects, uses, processes, and discloses in the course of its operations.

The purpose of this Policy is to provide information on our practices regarding Personal Information when you interact with us as a customer, supplier, vendor, healthcare professional or other general member of the public, as the case may be.

Additionally, this Privacy Policy provides information on specific practices regarding the Personal Information collected, used, processed, and disclosed:

  • Through Norwell Consumer Healthcare Inc.’s and its products websites (the “Websites”), including through forms found on our Website;
  • Information processed as part of medical information requests, product quality complaints and product related inquiries;
  • Information processed as part of reporting of safety information;
  • When you seek professional services, such as continuing education, webinars, and tele-expertise; and
  • When you interact with us or our representatives, as a consumer or as a healthcare professional, in the course of our operations.

 

Our consent policy regarding job applications is available through the application process.

I. PERSONAL INFORMATION WE MAY COLLECT

  • 1. Information Processed as Part of Operating our Websites
     

    Cookies. We may use cookies and other similar automatic data collection technologies to collect Personal Information whenever you visit or interact with the Website. This data helps us understand how you use the site features and the content of the Website in order to make improvements. We also use this data to promote our services through marketing and advertising.

    The information collected through Cookies includes:

    • Site Usage Information, such as session IDs to manage user sessions on the Website, and language preference information to tailor the Website to your preferred language; and
    • Marketing and Analytics Information, such as visitors, session and campaign data from your visits to our Website, in order to assist with playing videos on the Website, to track video views and usage, and to obtain information on website traffic, page visited, time and date of website visit, actions made during the website visit and which website features are used, which help us better understand how the website is used and the improvements we can make to the user experience.

    We use the services of web analysis third-party providers, such as Google’s Google Analytics service, Google ReCAPTCHA service, Google Ads Conversion Linker, Google Tag Manager, Microsoft UET, Amazon Web Services, Pinterest Tag, LinkedIn Tag, Floodlight, YouTube, Quantcast and Facebook (Meta) to assist us with the processing of information collected through cookies.

    You can opt-out of optional Cookies or prevent third-party websites from accessing our optional Cookies through the privacy settings on your browser. However, opting-out of our optional Cookies may disable some of our Website’s features and functionalities, and may prevent us from providing you with the information and services you have requested.

    Essential Cookies and related technologies are indispensable for the optimal operation and security of our Website. They enable Norwell Consumer Healthcare Inc. to safeguard your personal information and tailor your interface, preserving your preferences regarding the collection of personal information. Due to their key role in the functionality of our website, you cannot opt out of these essential cookies.

    Links to Third-Party Sites found on our Website: Our Website may include links to third-party websites as well as content and applications hosted and served by third-parties. Clicking on those links may allow the third-party to collect or share Personal Information about you. If you follow a link to a third-party website, please refer to the third-party’s privacy policy for information on the type of Personal Information it collects, and how it uses or discloses it. We do not endorse and are not responsible for the information or privacy practices of websites or services owned by third parties.

  • 2. Information Processed as Part of Medical Information Request, Product Quality Complaints and Product Related Inquiries
     

    You may provide us with some personal information when you complete online forms on our Website to send us requests for medical information or to make a product quality complaint. You may also contact us by email or through our phone line with inquiries.

    Information we may collect include:

    • Contact information.
    • Information related to the question, inquiry, or complaint; and
    • Information related to a specific product, in the event of a complaint or specific inquiry (e.g., product name, lot and expiry date).

    As part of these interactions, we may use the information you provide to us to:

    • Respond to your request, inquiry or complaint;
    • To monitor the safety of products and services;
    • To report, as necessary, adverse events to health authorities.
    • To improve our products and services; and
    • To comply with our policies and legal, regulatory, and compliance requirements.
  • 3. Information Processed as Part of Reporting of Safety Information
     

    You may provide us with some Personal Information when you complete online forms on our website to report adverse events, and other safety information related to the use of our products and when contacting us by email, our dedicated phone line. We may also receive personal information indirectly from partners or healthcare providers, regulatory agencies, social media, or other public sources, as the case may be. This information, which may include medical information, will be used by us for assessment purposes in the course of reviewing the report. If you choose to provide us with contact information, we may also use the information in order to contact you in the event we have any questions regarding the event.

    This information may include:

    • Direct identifiers such as names, email, addresses, phone numbers, age and gender;
    • Contact information of your healthcare professional(s);
    • Indications for which you are taking the product;
    • Information on the product (dosage/strength/route of administration);
    • Information on the adverse event, including the symptoms, diagnosis, medical condition, as well as the outcome of the event; and
    • Other relevant health information, for example, medical history, if other medications were taken and which, information on scenarios such as whether exposure happened during pregnancy or other circumstances.

    We may use this information to:

    • Contact you and/or your healthcare professional in order to obtain additional information;
    • Monitor the safety of products and services;
    • Report, as necessary, adverse events to health authorities;
    • Improve our products and services; and
    • Comply with our policies and legal, regulatory, and compliance requirements.

    We are required by law to collect this information about adverse events and the safety or quality of our products. As such, in some circumstances, we may be required to notify health authorities of certain information related to the use of our products. In these instances, we provide de-identified information to such authorities. We may also be required to exchange necessary safety information about our products to pharmaceutical partners to fulfill our pharmacovigilance obligations as required by law. In these instances, we provide de-identified information to such pharmaceutical partners, unless prior consent was given.

  • 4. Information Processed as Part of Establishing and Maintaining Relationships with Healthcare Professionals
     

    As part of our operations, specifically when we interact with healthcare professionals, we may process personal information. We collect this Personal Information from healthcare professionals and their place of work when we interact directly with them as well as when they register or attend events and training sessions. This information may be transferred by partners in the healthcare sector.

    For this purpose, we may collect the following Personal Information:

    • Identification information (e.g., name, first name, last name, gender, email and/or postal address, fixed and/or mobile phone number);
    • Professional information (e.g., title, name of place of work, academic and professional information regarding health profession (e.g., year of graduation from health programs, publications, specialty, awards, biography, education, links to universities, expertise and participation in/contribution to clinical trials, …);
    • Professional License Number (HCP Code) for the purpose of maintaining accounts on our Website;
    • Information regarding our products and services; and
    • Communication preferences with the health professional.

    We may use the Personal Information listed above for the following purposes:

    • To establish, improve and manage our interactions and our relationships with healthcare professionals (e.g., through our database and IT systems, as well as through our representatives);
    • To provide information related to our products and services;
    • To answer inquiries;
    • To track activities and interactions related to sales and calls;
    • To provide access to our Website portal related to Patient Support Programs;
    • To manage our internal resources, including IT and sales;
    • For billing and invoicing purposes; and
    • As allowed or required by law.

II. USE OF PERSONAL INFORMATION

In addition to the purposes specifically mentioned above, we may use Personal Information to comply with applicable laws, regulations, or legal process as well as industry standards and our company policies; to prevent, investigate, identify, or take any other action with regard to any suspected or actual fraudulent or illegal activity or any activity that violates our policies; and for any other purpose to which you provided consent.

III. DISCLOSURE OF PERSONAL INFORMATION

We may transfer Personal Information to third-parties who act on our behalf (i.e., service providers), for further processing in accordance with the purpose(s) for which the Personal Information was originally collected.

In the course of our activities and for the same purposes as those listed in this Privacy Policy, your Personal Information can be accessed by, or transferred to the following categories of recipients on a need-to-know basis to achieve such purposes:

  • Our personnel, including staff of Norwell Consumer Healthcare Inc. and its subsidiary Pharmascience Inc. on a need-to-know basis;
  • Our suppliers and service providers providing us with services and products;
  • Our third-party auditors as part of conducting audits for regulatory purposes;
  • Our system providers that provide us with IT solutions, including web service providers, cloud service providers, database providers; and
  • Our professional advisors, including lawyers, as part of requesting advice or as part of a business transaction involving part of our business or its assets.

Your personal information may be transferred in the event of a business transaction (e.g., merger, acquisition) to the buyer, assignee or transferee. Your Personal Information will remain protected in accordance with this Privacy Policy, or, should any change be made to the processing of your Personal Information, you will be notified through this Website.

Prior to any transfer of Personal Information, we ensure we have agreements in place holding third-parties to only use the Personal Information as necessary for the purposes for which the Personal Information was collected, to protect the Personal Information with security safeguards appropriate to the sensitivity of the information, and to not disclose it except as may be permitted by us, as required by law, or as stated in this Privacy Policy.

We may also disclose your Personal Information to a third-party if we are required to do so to comply with any court order, law (e.g., in the case of significant adverse events), or legal processes, including responding to any government or regulatory request, in accordance with applicable law, or when we believe disclosure is necessary or appropriate to protect our rights, property, or safety or the rights, property or safety of our customers, or others.

IV. HOW WE PROTECT PERSONAL INFORMATION

We use reasonable and appropriate security measures to protect Personal Information against unauthorized use, loss, access, modification, destruction, or disclosure while it is in our custody or under our control. These measures include physical, organizational, and technological measures that are proportionate to the quantity and sensitivity of the Personal Information. Part of these safeguards includes obtaining assurances from third-parties to require them to adopt practices that will provide a comparable level of protection for the Personal Information in its custody.

V. LOCATION OF YOUR PERSONAL INFORMATION

The Personal Information we collect is stored and processed in Canada and may be transferred outside of Québec and/or Canada to the recipients set out in Section III. Disclosure of Personal Information. Please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is stored, including lawful access. If your Personal Information is transferred outside of your jurisdiction, we will take steps to ensure your information receives adequate protection.

VI. DATA RETENTION

We will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it or meeting any legal or regulatory requirements.

VII. YOUR RIGHTS

You may choose to exercise any of the following rights related to your Personal Information. Some of these rights will be subject to specific requirements or limitations under applicable law:

  • Right to opt-out: You may “opt-out” or withdraw your consent at any time to the collection, use, disclosure, or any other form of processing of your Personal Information.
  • Rights of access, correction, and erasure: You may request access to and obtain a copy of any of your Personal Information that we hold, correction of any inaccurate, outdated or incomplete information related to you or deletion of your Personal Information under certain circumstances. You also have the right to request information on the types of Personal Information that are being collected and how these are processed.

If you wish to exercise any of these rights or make a complaint regarding our privacy practices, please contact us by sending an email or mail by using the contact information found in section IX. We will respond within the period specified by law. We may not accommodate a request if we believe it would violate any law or legal requirement. If we cannot accommodate a request, we will provide you with a justification. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service.

VIII. CHILDREN’S PRIVACY

While our Website and our services are not directed at children, in some cases, we may be required to collect, use and disclose the personal information of children (e.g., when reporting safety information). In those instances, we will gather the consent for the collection, use and disclosure of personal information from the child’s representative (e.g., parent or legal guardian). We may require some personal information to verify this representative’s authority to provide such consent. If Personal Information about children has been mistakenly provided to us and you would like to request that such Personal Information be removed, please refer to our Contact us section.

IX. CONTACT US

If you have any questions or comments about this Privacy Policy, or regarding your Personal Information, the ways in which we collect and use your Personal Information, or your choices and rights regarding such use, please contact our Privacy Officer at:

Email: cpo@norwellcanada.com

Mail Address: 6111 Royalmount Avenue, suite 750, Montreal (Quebec) H4P 2T4, Canada

X. UPDATES

We may update this Privacy Policy from time to time to reflect changes in our processing of Personal Information. If we change the way we collect, use, disclose or otherwise process your Personal Information, we will update this Privacy Policy and notify you, when required. These changes will take effect immediately upon posting. Where required by law, we may seek your prior consent.

Last modified: May 15th, 2024