Privacy Policy

Last updated April 27, 2021

LifeScan Canada ULC, (also referred to as “us”, “we” or the “Company”) is concerned about privacy issues and wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy describes our practices in connection with information that we or our service providers collect through the Web site or Web property (including, for example, a mobile Web site or application) operated and controlled by us from which you are accessing this Privacy Policy (the “Site”). By providing personal information to us or by using the Site, you actively agree to the terms and conditions of this Privacy Policy.

INFORMATION COLLECTION

 

Information You Provide

Some areas of the Site may ask you to submit personal information in order for you to benefit from specified features (such as newsletter subscriptions, tips/pointers, or order processing) or to participate in a particular activity (such as sweepstakes or other promotions). You will be informed what information is required and what information is optional.

The information we may collect includes:

  • personal and business contact information, such as name, title, address, telephone number and email address;
  • information that our sales representatives may collect during their visits with physicians and other health-care professionals with whom they deal, for instance title, qualifications, areas of practice or specialization, their questions or comments about our products, and related information about health-care professionals and their administrators relevant to maintaining and managing our relationship with such persons;
  • names and other contact details of patients who use our products and their physicians and, in certain circumstances, sensitive health information, and patient medical history, for example, where we have received a report of an adverse event, where we are providing patient-specific assistance with respect to the use or reimbursement of our products, or where we are assisting in or co-coordinating product recalls;
  • information collected in connection with inquiries or comments made by individuals who contact our Customer Care representatives;
  • names and other contact details of physicians participating in advisory boards and the opinions or comments expressed by those physicians during advisory board meetings;
  • names and other contact details of physicians involved in running clinical trials, together with their professional information such as curriculum vitae and other information that is required to be reported to Health Canada and other regulatory bodies;
  • information such as name, age, and gender of patients participating in clinical trials together with the clinical data collected in the course of the clinical trials. THE COMPANY generally receives patients' clinical data that has been recorded using identifiers other than the patients' full name, such as the patients' initials. More comprehensive patient data, including full names, may be reviewed by our clinical site managers when they attend at the trial site for compliance monitoring;
  • 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
  • other information with your consent or as permitted or required by law.

We may combine the information you submit with other information we have collected from you, whether on- or offline, including, for example, your purchase history. We may also combine it with information we receive about you from other sources, publicly available information sources (including information from your publicly available social media profiles), and other third parties.

 

Passive Information Collection and Use

As you navigate around the Site, certain information can be passively collected (that is, gathered without your actively providing the information), using various technologies. We and our third party service providers passively collect and use information in a variety of ways, including:

Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Site through a mobile device.

Using cookies: A "cookie" is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences. "Session" cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate and collect aggregate statistical information on the site. They are erased once you exit your web browser or otherwise turn off your computer. "Persistent" cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the website visitors find most valuable, and customizing the website based on your preferences on an ongoing basis.

You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site. You may also not receive advertising or other offers from us that are relevant to your interests and needs. To learn more about cookies, please visit http://www.allaboutcookies.org.

Using Flash cookies: Our use of Adobe Flash technology (including Flash Local Stored Objects (“Flash LSOs”)) allows us to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the Site, and collect and store information about your use of the Site. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Site or our online content.

Using pixel tags, web beacons, clear GIFs, or other similar technologies: These are smaller than cookies and tell the website server information such as the IP address and browser type related to the visitor's computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted.

Online behavioral advertising: The use of cookies, pixel tags, web beacons, clear GIFs, or other similar technologies allows our third-party vendors to deliver advertisements about our products and services when you visit the Site or other web sites or web properties across the Internet. These vendors may place pixel tags, web beacons, clear GIFs, or similar technologies on the Site and other websites or web properties, and also place or recognize third-party cookies when you visit the Site or other sites or web properties. They may use information about your visits to the Site and other web sites or web properties to provide advertisements about goods and services that may be of interest to you.

IP Address: A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider. In most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site. The Company, or its authorized agents, use this information to collect and report aggregate information on how the website is being used and ways in which the website can be improved.

Device Information: We may collect information about your mobile device, such as a unique device identifier.

How We Use and Disclose Information

 

We use and disclose information you provide to us as described to you at the point of collection.

We also use information from or about you:

  • to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail alerts;
  • to send you important information regarding our relationship with you, such as health and product-related information, or regarding the Site, changes to our terms, conditions, and policies and/or other administrative information;
  • to test and analyze our products for efficacy and safety, such as receiving and assessing product inquiries, reports of adverse events, and product complaints, and to assist in or co-ordinate product recalls;
  • for our business purposes, such as data analysis, audits, developing and improving our products, enhancing our website, improving our services, identifying Site usage trends, personalizing your experience on the Site by presenting products and offers tailored to you, determining the effectiveness of our promotional campaigns, and establishing our relationship with health-care professionals and administrators; and
  • to evaluate resumes or other personal information submitted to us in connection with employment possibilities. 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 the Company.

We also disclose information collected through the Site:

  • to our affiliates for the purposes described in this Privacy Policy. The Company is the party responsible for the management of the jointly-used Personal Information;
  • to our third party partners with whom we offer a co-branded or co-marketed promotion;
  • to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, credit card processing, auditing services, and other services, in order to enable them to provide services; and
  • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction or business relationship and to fulfill reporting or audit requirements).

In addition, we use and disclose information collected through the Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose information collected through the Site in other ways, with your consent. We also use and disclose information we collect passively as described above, under “Passive Information Collection and Use,” and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined. The Company will limit the collection and use of both the amount and the type of personal information to that which is necessary to fulfill the identified purpose at the time of collection or as identified above.

THIRD PARTY SITES AND SERVICES

 

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on the Site does not imply endorsement of it by us or by our affiliates.

SECURITY

 

We use reasonable organizational, technical, and administrative measures to protect personal information under our control. The Company will take appropriate steps to ensure that personal information about you is protected from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. You should take special care in deciding what information you send to us via email or posting on our websites. Moreover, where you use passwords, ID numbers or other special access features on our websites, it is your responsibility to safeguard them. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

 

Your choices regarding our use and disclosure of your personal information

We give you choices regarding our use and disclosure of your personal information for marketing purposes. Consent can be express (express consent may be oral, in writing or electronic), implied (such as when you provide your name and address in order for us to send you products 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). 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.

 

Opt In

In some cases you will, at the point of collection of the information, be given the option to "opt in". The act of "opting in" constitutes your express consent to receive future communications that may be of relevance to you. You can 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 a website, or by doing some other specified action such as contacting us by telephone or by email, or by signing a consent form on which your personal information is requested. Your personal information will in such case only 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 information about, or special offers for Company products, in which case you will receive information relating to those brands and programs of the Company that we believe may be of interest to you. By "opting in" to offers from the Company, you are indicating your agreement to automatically receive communications regarding any brands or programs of the Company that we believe will be of interest to you. Alternatively, for certain brands or specific programs, where offered, if you wish to receive information relating only to specific brands and related programs or only to specific programs, you will have the option to "opt in" separately for these. After you "opt in" to receive offers or programs, you will have the option to "unsubscribe" or withdraw your consent if you no longer want to receive communications, either by following the instructions in an email we send you or by contacting us by other means, as described below.

When you wish to participate in a promotion, contest or survey, engage or participate in discussions, promotions or otherwise interact on our websites, or to purchase a product you will not be required, as a condition of your participation or purchase of the product, to provide more personal information than is necessary or legally required in order for us to administer the promotion, contest or survey, facilitate the discussion or to deliver any products you may be entitled or wish to receive. However, you may be provided with the option of providing additional personal information. You may, for example, choose to provide additional personal information by completing a questionnaire on a contest ballot relating to your use of our products, in which case we may then use that information to assist us in developing, improving, and selling our products or improve your interactions on our websites.

 

Withdrawing Consent

You may opt out from: privacy@lifescancanada.com(link sends email)

  • Receiving marketing communications from us: If you no longer want to receive marketing communications from us on a going-forward basis, you may opt out of receiving them by sending an email to privacy@lifescancanada.com(link sends email). In your response to us, please provide your name, identify the form(s) of marketing communications that you no longer wish to receive, and include the address(es) to which it/they are sent. In addition, you may opt out of receiving marketing e-mails from us by following the unsubscribe instructions provided in any such message.
  • Receiving reminders from us: If you no longer want to receive medical reminders from us on a going-forward basis, you may opt out of receiving them by sending an email to privacy@lifescancanada.com(link sends email). In your response to us, please provide your name and the e-mail address or phone number at which you receive reminders from us.
  • Our sharing of your personal information with affiliates and third-party partners: If you would prefer that we not share your personal information on a going-forward basis with our affiliates and/or third-party partners for their marketing purposes, you may opt out of this sharing by sending an email to privacy@lifescancanada.com(link sends email). In your response to us, please state that we should no longer share your personal information with our affiliates and/or third-party partners for their marketing purposes, and include your name and e-mail address.

We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your personal information from the databases of our affiliates with which we have already shared your information (i.e., as of the date that we implement your opt-out request). Please also note that if you opt out of receiving marketing-related messages from us, we may still send you important transactional and administrative messages, from which you cannot opt out.

 

How you can access, change, or delete your personal information

If you would like to review, correct, update, or delete the personal information that you have provided via the Site, please refer to the “Contacting Us” section below. We will take reasonable steps to verify your identity before granting access or making corrections. We will respond to you within thirty (30) days after the written request for access or rectification has been received or will notify you during that period if a longer period is required by us in order to fully address your request, provided that an extension of such thirty (30) day period is permitted by applicable privacy laws.

 

Access Exceptions

Some information may not be accessed in certain limited circumstances. In some cases, for example, the following exceptions may apply:

  • information that contains references to other individuals and such information is not severable from your personal information;
  • information the disclosure of which would reveal confidential commercial information; and
  • information that is subject to solicitor-client or litigation privilege

The Privacy Officer must approve all exceptions to access. The reasons for denying access shall be provided by the Company upon request.

RETENTION PERIOD

 

We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

USE OF SITE BY MINORS

 

This Site is not directed to individuals under the age of 13, and we request that these individuals not provide Personal Information through the Site. If a child under 13 has provided us with personal information, we ask that a parent or guardian of the child contact us to request that this information be deleted from our records. We will use reasonable efforts to delete the child's information from our existing files.

CROSS-BORDER TRANSFER

 

Your personal information may be transferred to outside agents or service providers (including affiliates acting in this capacity) that perform services on our behalf, for example: certain payroll and benefits administration functions; receipt and administration of certain adverse event or product quality complaints; certain credit card, billing, mailing, marketing, information technology and/or data hosting or processing services, or similar services; or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy. Some of these service providers may be located outside of Canada, including in the United States, which may provide for different data protection rules.

Please refer to the “Contacting Us” section below in order to find out how to obtain access to written information about our practices with respect to service providers outside of Canada and the title of the person who is able to answer, on behalf of the Company, questions you may have about a) the service providers outside Canada who may collect, use, disclose, access, store your personal information; b) the purposes for collecting, using, disclosing, accessing or storing your personal information; or c) where information will be held or the categories of persons who will have access to it.

UPDATES TO THIS PRIVACY POLICY

 

We may change this Privacy Policy at any time. Please take a look at the “Last Updated” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.

CONTACTING US

 

You may contact us as described below in order to:

  • receive a copy of the most current version of our Privacy Policy or our procedures regarding the use of third party providers outside of Canada;
  • communicate any questions, comments, or concerns about our Privacy Policy or personal information handling practices or to request additional information;
  • request to withdraw your consent to our retention, use or disclosure of your personal information; or
  • request access to or correction of your personal information.

Requests regarding items 3 and 4 above must be made in writing. Requests are subject to some access exceptions as prescribed by law and identified above under “Access Exceptions”. Any exceptions to providing you with access to your personal information must be approved by the Privacy Officer. Any communication, comments, ideas, concepts, know-how, techniques, material or other information (collectively, the “Communication”) that you voluntarily post or transmit to the Company by email is, and will be treated as, non-confidential and non-proprietary. By transmitting any Communication to us by email, you grant to the Company and all of its affiliates, an unrestricted, irrevocable license to use, reproduce, display, modify, transmit, distribute, publish, broadcast or post your Communication for any purpose. However, we will not release your name in connection with such Communication unless: (a) you grant us permission to do so; (b) we first notify you that the Communication you submit to a particular part of the website will be published or otherwise used with your name on it; or (c) we are required to do so by law.

You may contact us by:

CA-GEN-2100010