• contact information, such as names, addresses, e-mail addresses, or telephone numbers
• information about a customer’s condition or treatment that is voluntarily provided to us
• information about an individual’s use of LifeScan Canada or similar products
• titles and qualifications of health care professionals and representatives we deal with
• records of customer service calls or product-related comments or inquiries
  

• occasionally communicate with you about products, services, and promotions or for market research (e.g. by mail, e-mail or telephone offers, or surveys), and send you similar material about related products and services of other companies, if you have consented to receiving these communications from us (see “Withdrawing Consent”)
• provide customer service relevant to your circumstances and respond to your inquiries
• improve our products and services
• provide you with important product notifications
• administer promotions and contests
• administer product investigations or recalls, where necessary
• manage our relationship with health care professionals and representatives
  

• to LifeScan Canada’s Canadian affiliates, who may have access to your personal information if you have consented to receiving information about their products and services (see “Withdrawing Consent”)
• to service providers LifeScan Canada uses to support its business (e.g. call centre, data warehouse, market research, and similar services)
• to certain affiliates and/or government health authorities in order to facilitate a recall or comply with applicable health and medical device regulations

For more information about disclosure of personal information, please refer to the Policy under “Disclosure”.

Withdrawing Consent
You will generally be given the opportunity when your personal information is collected to refuse or withhold consent to our use of personal information for marketing purposes, or sharing of personal information to our Canadian affiliates for their marketing purposes. To contact us about withdrawing consent to our use or disclosure of personal information, you can call us at 888 534-9991 or contact us as otherwise described below.

Personal Information Access
Individuals may access or correct their personal information held by LifeScan Canada, subject to legal restrictions. Personal information access requests should be submitted in writing to the Chief Privacy Officer at the address provided below. For more information or assistance in accessing your personal information, you can contact LifeScan Canada as described below.

Personal Information Storage and Security
LifeScan Canada stores personal information in the Johnson & Johnson Canada Consumer Data Warehouse, managed at our offices in Toronto, Ontario, and in our technical services database hosted by our affiliates in the United States. LifeScan Canada has implemented physical, electronic, and managerial procedures designed to protect the integrity, security, and appropriate use of personal information to prevent unauthorized access.

For More Information
You may view or obtain a copy of the complete LifeScan Canada Privacy Policy. You can also obtain a copy of the policy or make other inquiries about your personal information by calling 888 534-9991, sending an e-mail, or writing to:

Chief Privacy Officer
LifeScan Canada Ltd.
300 - 4170 Still Creek Drive
Burnaby, BC
V5C 6C6

LIFESCAN CANADA LTD. PRIVACY POLICY
This Privacy Policy is designed to tell you about the practices of LifeScan Canada Ltd. (“LifeScan Canada”) regarding collection, use and disclosure of personal information (that is, information that can be uniquely identified with you, such as your full name, address, e-mail address, phone number, health information, information about your use of our products that you may voluntarily provide to us, and comments or inquiries you have made about our products), including personal information you provide via our Web site, through forms, over the telephone, and by mail or facsimile. References to personal information in this Privacy Policy do not, however, generally include contact information of an employee of an organization, i.e. name, title, business address, or business telephone number. Please be sure to read this entire Privacy Policy before providing us with any of your personal information. This Privacy Policy applies to individuals we deal with in Canada including consumers, patients, health care professionals, sales representatives or others within the health care or pharmaceutical industries, including individuals who purchase, use or dispense, or want information about, our products, and potential employment candidates. This policy does not apply to our employees or to information that is not personal information.


Contacting Us
This Privacy Policy refers in various places to you contacting us in order to:
1) receive information or special offers
2) withdraw your consent to our retention, use and disclosure of your personal information
3) access or correct your personal information
4) request that personal information about a child under the age of 13 be deleted from our records
5) receive a copy of the most current version of this Privacy Policy
6) communicate any questions, comments, or concerns about this Privacy Policy or the information practices of LifeScan Canada.

You may contact us for any of these by:
1) writing to us, attention:

Chief Privacy Officer
LifeScan Canada Ltd.
300-4170 Still Creek Drive
Burnaby BC
V5C 6C6

2) calling our toll free number 888 534-9991
3) sending us an e-mail to privacy@lifescancanada.com
4) faxing us at 604 293-1619, attention Chief Privacy Officer, LifeScan Canada.

Requests regarding access or correction of personal information must be made in writing.


Collection, Use and Disclosure of Information
Collection: We collect your personal information where you provide it to us voluntarily or otherwise with your consent or as permitted or required by law. We may collect your personal information when you:
(a) Request information to be sent to you
(b) Contact us about our products and services
(c) Complete and send us our product training forms or warranty cards
(d) Register or otherwise provide information on our Web site (as described below)
(e) Participate in marketing promotions
(f) Fill out questionnaires or surveys
(g) Purchase and order delivery of our products
(h) Participate in programs and/or promotions from other Canadian affiliates of Johnson & Johnson and consent to receiving information from us
(i) Provide information to us in your capacity as a heath care professional or health care industry representative
(j) Submit your resume or other personal information in connection with employment possibilities with us
(k) Otherwise provide your personal information by telephone, by mail or through our Web site.

Types of personal information LifeScan Canada and its agents and representatives may collect include:
(a) Personal or business contact information, such as name, title, address, telephone number and e-mail address
(b) Information about your training on our products that your pharmacist may provide to you, and additional information about your health and use of diabetes control and other health products that you may voluntarily provide to us
(c) Names and other contact details of patients who use our products and their physicians and, in certain circumstances, health information, which may be collected in circumstances where we have received a report of an adverse event, where we are providing patient-specific assistance with respect to the use of our products, or where we are assisting in or coordinating product recalls
(d) Inquiries or comments about our products that are provided by individuals who contact our sales or company representatives or our toll-free number
(e) Information that our sales representatives may collect during their contacts with health care professionals and industry representatives with whom they deal, for instance title, qualifications, areas of practice or specialization, their questions or comments about our products, and related information relevant to maintaining and managing our relationship with those professionals and representatives
(f) Information contained in resumes or related information you may provide to us, or that we may collect, in connection with an application for employment
(g) Information from individuals visiting our premises such as their name and the name of the organization for which they work or which they represent. We may also post video cameras in public-access areas on our premises and will post signs notifying individuals of the existence and purpose of any such cameras.

Some areas of our Web site may ask you to submit personal information in order for you to register at our site, register your product, benefit from the specified features (such as newsletter subscriptions, tips, points, order processing or resume submission) or to participate in a particular activity (such as promotions and surveys). Some features of our Web site may request optional information about your health and use of health products in order to understand your needs or provide more relevant information to you. You will be informed what information is required and what information is optional.

LifeScan Canada collects personal information otherwise with your consent or as permitted or required by law.

Use: We will use your personal information in order to:
(a) Reply to your requests, inquiries and comments
(b) Confirm and keep records of product training provided to you
(c) With your consent, send you occasional educational and diabetes-related information about products, services, samples, and promotions offered by LifeScan Canada or third parties that offer related products and services, and/or contact you to conduct telephone surveys and similar market research
(d) Develop and implement brand and consumer marketing programs that specifically tailor consumer offers or communications to your specific needs based on personal information that you have provided to us, including your product or purchasing preferences or requirements, or information about your health and use of health products you may voluntarily provide to us
(e) Provide customer service that you may request, including service specifically tailored to your needs and circumstances based on health, product and other information you may have voluntarily provided
(f) Administer promotions when you have completed and provided to us ballot or entry forms or requested communications regarding any of our promotions
(g) Keep records of users of our products to provide important product information and notifications, such as product recalls
(h) Improve our products and services based on personal information you have provided to us, including personal information provided in questionnaires, forms or surveys
(i) Fill and process product orders that you have placed with us
(j) Establish and maintain our relationship with health care professionals or others in the health care industry, including providing assistance and advice to health care professionals and representatives of health care organizations with respect to our products
(k) Evaluate resumes or other personal information submitted to us in connection with employment possibilities, to assess whether to offer the employment candidate a position at LifeScan Canada. For candidates who are not offered or do not accept a position, we may retain their information in the event that an appropriate position becomes available or that they re-apply to LifeScan Canada
(l) Receive and assess product inquiries, reports of adverse events, and product complaints
(m) Manage our business, including customer relations, accounting and record-keeping
(n) Meet legal, regulatory, ethical, and processing requirements such as adverse event reporting requirements to Health Canada and regulatory bodies, and ensure the security and integrity of our Web site and operations.

We may also use your personal information for other purposes that are disclosed at the time of collection, or otherwise with your consent or as permitted or required by law.

Your personal information may be transferred to agents or service providers, including our affiliates acting in this capacity, that we use to support our business (e.g., call centre, data warehousing, market research, fulfilment, technical support, delivery, printing, and credit card processing services), including in other jurisdictions such as the United States. We will use contractual or other means to require such agents or service providers to protect your personal information and not disclose it for any purpose other than as directed by us, subject to legal requirements in other jurisdictions applicable to us or our agents and service providers. Note that some of these jurisdictions do not have personal information protection laws equivalent to those in Canada.


Disclosure: Your personal information will be stored in the Johnson & Johnson Canada Consumer Database. Depending upon the consent you have provided (see the section on "Consent"), Johnson & Johnson Canadian Affiliates may have access to your personal information that is stored in the Johnson & Johnson Canada Consumer Database, in order to permit these affiliates to send you occasional information about their products and services in accordance with your consent. “Johnson & Johnson Canadian Affiliates” are McNeil Consumer Healthcare, a division of McNeil PDI Inc., LifeScan Canada Ltd. and Johnson & Johnson Inc. (including its divisions Johnson & Johnson Medical Products and Johnson & Johnson Vision Care). Johnson & Johnson Canadian Affiliates are obligated to treat your personal information substantially in accordance with this Privacy Policy.

In the event we need to recall a product, Canadian medical devices regulations require that LifeScan Canada provide Health Canada with the name of each person to whom the affected device was sold by the manufacturer or importer (for instance to pharmacists or organizations in our trade channel) and the number of affected units sold to each person. In the event of a recall, LifeScan Canada may also disclose to Health Canada the names and contact details of consumers who have purchased our products and whose information we have otherwise obtained, for the purpose of coordinating or assisting in the recall.

Your personal information may be used by LifeScan Canada and disclosed to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of any of the Johnson & Johnson Canadian Affiliates’ business or assets, including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction or business relationship, to fulfil reporting or audit requirements to those parties, or the use and disclosure by those parties for substantially the same purposes as described in this policy.

LifeScan Canada may otherwise disclose your personal information with your consent, or as otherwise permitted or required by law.


Consent
Consent to the collection, use, and disclosure of your personal information may be given in various ways. Consent can be express (express consent may be oral, in writing or electronic), implied (such as when you provide your name and/or address in order for us to send you products you have ordered or information you have requested) and may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with your personal information, we will assume that you consent to our collection, use and disclosure of such information as described in this Consumer Privacy Policy. However, you may be asked to “opt-in”:

Opt-in: In some cases you will, at the point of collection of the information, be given the option to “opt-in” in order for you to provide your express consent to our collection, use and disclosure of such information by checking a box on a form, clicking on a specified icon on our Web site or by doing some other specified action such as contacting us by telephone or by e-mail. Your personal information will in such case be collected, used or disclosed for the purposes we describe at that time if you “opt-in”. You will, for example, have the option to “opt-in” to receive occasional communications and diabetes-related information about products, services, samples, and promotions from us. Additionally, LifeScan Canada may offer you the opportunity to opt-in to receive information about Johnson & Johnson Canadian Affiliates’ products, services and promotions, in which case, if you opt-in, you will receive information relating to those affiliates’ brands and programs that we believe may be of interest to you, and these affiliates may have access to your personal information on the Johnson & Johnson Canada Consumer Database to communicate with you for this purpose. After you “opt-in” to receive offers or programs from LifeScan Canada or from the Johnson & Johnson Canadian Affiliates, you will have the option to “unsubscribe” or withdraw your consent if you no longer want to receive certain of the offers and programs, or have your personal information made available to our Canadian affiliates for this purpose, either by following the instructions we send you via email, or mail or by contacting our customer service centre at 888 534-9991.

When you wish to purchase a product or obtain an offer or promotion, you will not be required, as a condition of purchasing such product or obtaining such offer or promotion, to provide more personal information than is necessary in order for us to deliver to you the product, offer or promotion. However, you may be provided with the option of providing additional personal information, for instance information about your health condition or history or use of LifeScan Canada’s or similar products. You may, for example, choose to provide additional personal information by completing a questionnaire on a contest ballot relating to your product preferences, or complete the health questionnaire on our product training or product registration forms, in which case we may then use that information to assist us in developing and improving our products, and to tailor our offers and communications to meet your specific needs, if you have consented to receiving such offers and communications.

If you do not want your personal information collected by us, please, 1) do not submit personal information to us, or 2) do not “opt in”, where such option is available, so that your personal information is not used or disclosed for the purposes described at the time of collection. If you have submitted personal information and wish to withdraw your consent to its retention, use or disclosure, please contact us. You may withdraw your consent, subject to legal or contractual restrictions and reasonable notice.

Collection, Use or Disclosure Without Consent: In certain limited circumstances the collection, use or disclosure of personal information without consent is permitted by law. For example, your personal information may be disclosed without consent if the disclosure is made to our lawyers or for the purpose of collecting outstanding amounts owed to us.


About Children
Children under the age of 13: We do not intend to collect personal information from individuals under the age of 13. We encourage parents to talk to their children about their use of the Internet and the information they disclose to Web sites or otherwise.

We will use reasonable efforts to delete all contact and other personal information obtained from a child if a parent or guardian notifies us that they wish to withdraw consent for the collection of a child's information.


About Information Collection on the LifeScan Canada Web Site
Active Information Collection: LifeScan Canada’s Web site actively collects information from its visitors both by asking you specific questions and by permitting you to communicate directly with us via e-mail and/or feedback forms. Some of the information that you submit on the Web site may be personal information. Collection, use, and disclosure of information actively collected from you have been described.

Passive Information Collection: As you navigate through the LifeScan Canada Web site, certain anonymous information can be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or Web beacons, and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the Web site some of this anonymous information, such as the URL of the Web site you just came from and the Internet Protocol (IP) address and the browser version your computer is currently using. The LifeScan Canada Web site may also collect anonymous information from your computer through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of the Web site might not work without cookies.

The LifeScan Canada Web site may use and combine such passively collected anonymous information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the sites for your use. Such passively collected anonymous information is not combined with personal information collected elsewhere on the Web site, unless you have consented to have your personal information collected in conjunction with this passive information.
Learn more about cookies and other passive tracking methods.


Access and Correction: We will establish and maintain a file of your personal information for the above-mentioned purposes. Your file will be stored at Toronto, Ontario. At your request, we will take appropriate steps to update or correct personal information in our possession that you have previously provided to us. Please contact us in writing:

attn. Customer Records
LifeScan Canada Ltd.
300-4170 Still Creek Drive
Burnaby, BC
V5C 6C6

if you would like to request access or correction of your personal information. We may need to verify your identity before searching for or providing you with your personal information. Some information may not be accessed in certain limited circumstances, for example, if it is protected by solicitor-client privilege or cannot be disclosed for legal reasons.


Security: We have implemented physical, electronic and managerial procedures designed to protect the integrity, security and appropriate use of your personal information and to prevent unauthorized access. Authorized employees, agents, and mandataries of LifeScan Canada, who require personal information to fulfil the purpose for which the information was collected, are permitted to access personal information in accordance with the consent provided (see the section on Consent).

Although we have enacted security measures, we cannot guarantee the security of any information that you submit electronically, which is done at your own risk, since no Internet transmission is ever 100% secure or error-free (in particular, e-mails sent to or from LifeScan Canada may not be secure). You should take special care in deciding what information you send to us via e-mail or posting on the LifeScan Canada Web site. Moreover, where you use passwords, ID numbers, or other special access features on the LifeScan Canada Web site, it is your responsibility to safeguard them.

Links to Other Web Sites: The LifeScan Canada Web site may contain links or references to other Web sites to which this Privacy Policy does not apply. LifeScan Canada is not responsible for the data collection and use practices of companies or organizations to which the LifeScan Canada Web site may provide links. We encourage you to read the Privacy Policy of every Web site you visit.


Changes to This Privacy Policy
We reserve the right to change this Privacy Policy at any time and we will take reasonable steps to advise affected individuals of any material changes. Please check periodically at our Web site, and especially before you provide any personal information, to ensure you are aware of and accept any changes made. For example, your continued consent to our collection, use and disclosure practices following notification of any material change and/or your continued use of this Web site following the posting of any material changes to this Privacy Policy shall constitute your acceptance of those changes. You may also contact our Chief Privacy Officer as described above.


Questions, Comments, Concerns
Please contact us if you have any questions, comments or concerns about our use of personal information or about this Privacy Policy. LifeScan Canada will investigate any complaint you may have regarding our use of personal information and comply fully with the legal and regulatory supervisory authorities responsible for enforcing our adherence to the privacy principles stated in this Consumer Privacy Policy. This Privacy Policy was last updated August 30, 2005.