This research-based pharmaceutical company (the "Company") is committed to controlling the collection, use and disclosure of personal information.

The Company collects, uses and discloses various types of personal information in carrying on business, including information about health care professionals (including physicians, pharmacists and other health care workers), patients, participants in clinical studies, customers and employees.

The Company collects, uses and discloses personal information in accordance with the following ten fair information principles.

Collecting Personal Information

In carrying on its business, The Company collects various types of personal information including personal information about healthcare providers (including physicians, pharmacists and other healthcare workers), patients, participants in clinical studies, and customers. Personal information that we collect may include:

Using Personal Information

The Company generally uses personal information for the following purposes:

Business Transactions

Personal information may be used by The Company and disclosed to parties connected with a proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of The Company or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of The Company or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

Service Providers

The Company may transfer personal information to outside agents or service providers (including our affiliates acting in this capacity) for reasons such as data processing, data warehousing, administrative services, conducting programs, and otherwise collecting, using, disclosing, storing or processing personal information on The Company's behalf for the purposes described in this Privacy Policy. The Company uses reasonable contractual or other means to require third parties to commit to protecting personal information to a level comparable to that provided by The Company. Some of these service providers may be located outside of Canada and your personal information may be collected, used, disclosed, stored and processed in these jurisdictions for the purposes described in this Privacy Policy. While your personal information is located outside Canada it will be subject to the laws of the jurisdiction in which it is retained, including laws that may require disclosure of personal information to foreign government authorities.

Our website and the Internet

IP Addresses and Server Logs

The nature of the internet is such that it passively and automatically collects certain information about a user's traffic patterns linked to their Internet Protocol (IP) addresses. These are unique Internet "addresses" assigned to all web users by their Internet Service Providers (ISP). IP addresses are automatically logged by web servers. While the IP address does not generally identify an individual on its face, it may, with the cooperation of the ISP, be used to locate and identify an individual using the internet.

The Company's servers automatically log information about visits to our website in the normal course of establishing and maintaining web connections. Server logs record statistical information, such as visitors' IP addresses, type of operating systems, time and duration of visit, web pages requested, and identify categories of visitors by items such as domains and browser types. These statistics are reported in aggregate form to The Company and are used to improve our website and ensure that it provides the optimal web experience for visitors.

The Company does not link server log information to any other data in a way that would enable us to identify individual visitors. However, we may review server logs for security purposes, for example, to detect intrusions into our network.


As with many other websites, our site makes use of session and permanent "cookie" technology. Cookies are small text files that contain a unique identification number that is automatically deposited on a visitor's computer. This information helps us determine, in the aggregate, the total number of visitors to the site on an ongoing basis and the types of internet browsers and operating systems used by our visitors. This information is used to facilitate and enhance your online visits. We do not cross-reference the information automatically collected through "cookies" with any type of personal information that is voluntarily offered on or through this website.

The use of cookie technology is common on the Internet, and many internet browsers are initially configured to accept cookies automatically. If you would prefer not to accept cookies, you can set your internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. However, if you refuse to accept cookies, this may limit your use of the website.

Other websites to which the The Company website provides links are governed by different privacy policies. The Company does not assume responsibility for the content or information practices of these other websites, and we strongly encourage all web visitors to review the privacy statements and policies of all externally-linked sites.

Your Consent

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide personal information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an "opt-out" option provided, if any. The form of the consent sought by The Company, including whether this consent is express or implied, may vary depending upon the circumstances and the type of personal information. In determining the form of consent to use, The Company will take into account the sensitivity of the personal information and the reasonable expectations of the individual. Generally, by providing us with your personal information, we will assume that you consent to our collection, use and disclosure of such personal information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection.

If an individual is not capable of consenting to the collection, use or disclosure of his or her own personal information, consent must be obtained from the person who is legally entitled to consent on behalf of the individual.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. The Company will inform you of the implications of withdrawing consent. In certain circumstances, you may not be permitted to withdraw consent to certain necessary uses and disclosures of the personal information for which your consent was originally collected.

The Company collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.


The Company implements reasonable security safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the personal information is held.

The methods of protection include:

Access and Correction

The Company maintains a file of personal information for individuals for the purposes described in this Privacy Policy, which will be accessible at the address provided in the Contact Information section below. If you wish to request access to or correction of your personal information in our custody or control, you may write to this address, attention Privacy Compliance Officer. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections.For more information about the collection, use and disclosure of personal information, including about personal information that is collected, used, disclosed, stored or processed outside of Canada, you may contact us using the contact information listed below.

Privacy Policy Changes

This Privacy Policy may be revised from time to time. We urge you to request and review this Privacy Policy frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of any such changes. This Privacy Policy is effective as of April 4, 2012.

Contact Information

Accountability for compliance by The Company with privacy policies and procedures rests with the Privacy Compliance Officer, even though other individuals within the company may be responsible for the day-to-day collection and processing of personal information. In addition, the Privacy Compliance Officer may, from time to time, designate one or more other individuals within the company to act on his or her behalf, including representatives from all areas of the business.

The contact information for The Company's Privacy Compliance Officer is:

Privacy Compliance Officer
1004 Middlegate Road
Mississauga, Ontario
Canada L4Y 1M4
Tel: 905-803-4883 (ext. 4883)