Last Updated: September 13, 2012
- This Policy does not apply to the collection, use, and disclosure of Personal Information by third-parties, where Sanofi Canada does not have any control over the collection of Personal Information or over their respective privacy practices.
- Except for legal and regulatory requirements applicable to Sanofi Canada and for the Purposes outlined herein at Section 10, Sanofi Canada, its employees and service providers, do not have access to any Personal Information.
- By “Personal Information” we mean any information collected, used by or on behalf of Sanofi Canada enabling to 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, health related information.
- Sanofi Canada is committed to privacy and the protection of Personal Information and this Policy complies with the Personal Data Protection Charter of the Sanofi Group and with applicable Canadian personal information and privacy laws and regulations
Collection Of Personal Information
- Sanofi Canada may collect the following types of Personal Information:
- name, postal address, email address, telephone number, date of birth
- 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
- information necessary to complete a sale transaction such as a credit card number for processing an order via one of our online websites.
- Personal Information may be collected in the following manner:
7.1 information provided by you
- when contacting us or communicating with us via the 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 fields queries
- when using one of our electronic or mobile devices, applications or tools
- when registering for a warranty in relation to one of our products
- when participating in a clinical trial or research
- when submitting your resume to us for employment purposes
7.2 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.
7.3 information derived from public sources or provided by service providers which information services are governed by separate rules of protection of Personal Information.
8. As the case may be, the collection of Personal Information may be governed by a disclosure document requiring your acceptance.
9. 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.
10. 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 enable us to create your profile, customize and personalize the content, tools and resources available to you as a member of one of our websites, online resources or mobile devices, applications or tools and to grant you access to interactive tools which may be available such as blogs and forums
- to grant you access to one of our mobile devices, applications or tools
- to process a sale transaction for one of our products or services
- 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
- to allow us to assess your employment application
11. 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.
12. 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.
Information We Share
13. 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.
14. Personal Information about you will be accessible only to authorized employees of Sanofi 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.
16. 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).
17. The collection, use, and disclosure of information contemplated in this 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.
18. 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.
19. Sanofi 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 Sanofi Canada and/or its affiliates who need to access the information in connection with the Purposes.
20. 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.
22. Sanofi Canada respects and observes 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 an individual pursuant to the Act or any such other applicable privacy legislation, and same is not set forth herein, Sanofi Canada agrees to take such measures to give full effect to such additional protection.