1.2 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.
1.3 By “Personal Information” we mean any information collected, used by or on behalf of Sanofi Canada enabling it to directly or indirectly 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, Internet protocol (IP) address used to connect your computer to the Internet, and health-related information
1.4 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 available at: https://www.sanofi.com/en/our-responsibility/sanofi-global-privacy-policy and with applicable Canadian personal information and privacy laws and regulations.
3. Collection of Personal Information
3.1 Sanofi Canada may collect the following types of Personal Information:
- name, postal address, email address, telephone number, date of birth;
- Internet protocol (IP) address used to connect your computer to the Internet;
- 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; and
- information necessary to complete a sale transaction such as a credit card number for processing an order via one of our online websites.
3.2 Personal Information may be collected in the following manner:
3.2.1 information provided by you:
- when contacting us or communicating with us via 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 field 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; and
- when submitting your resume to us for employment purposes;
3.2.2 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;
3.2.3 information derived from public sources or provided by service providers which information services are governed by separate rules of protection of Personal Information;
3.2.4 information derived from visitor tracking data. More specifically, Sanofi Canada measures the performance of its sites in order to improve and customize them in favour of our visitors. During your visit, Sanofi Canada automatically collects and temporarily stores information about your computer and your visit.
Sanofi Canada websites may use a tracking technology called a “cookie”. A “cookie” is a small text file that a website can place on your computer’s hard drive in order, for example, to collect information about your activities on the site, to track your preferences and selections, or to show you advertisements based on your interests, such as banner ads relating to Sanofi Canada products and services. Cookies may be placed on your computer by Sanofi Canada or by another company or advertiser that Sanofi Canada engages to provide services or advertising (a “third party cookie”).
It is possible that these cookies could be used in combination with other information to identify you. Information stored in first party cookies associated with a Sanofi Canada website will be transmitted back to us. Information stored in third party cookies may be transmitted to the party placing the cookie, so that they can deliver to you messages and advertisements based on your interests as you browse the Internet.
You may be able to opt out of third parties using cookies to deliver interest-based advertising to you by visiting www.aboutads.info/choices/ or https://www.networkadvertising.org/choices/. With most internet browsers, you can also erase cookies from your computer’s hard drive, block all cookies, block specific kinds of cookies, or even receive a warning before a cookie is placed on your system. Refer to your browser instructions or help button to learn more about cookies. You should be aware, however, that cookies might be necessary to provide you with certain features (e.g. customized delivery of information) available on Sanofi Canada websites.
3.2.5 Web Logs
Sanofi Canada websites may also automatically collect and store web log information relating to your computer and your visit, such as the name of the domain and host from which you access the Internet; the Internet address of the website from which you linked to a Sanofi Canada website; the date and time you accessed a Sanofi Canada website, how long you spent and which pages you visited; your computer’s operating system and browser software; and your Internet protocol (IP) address. An IP address is a number assigned to your computer by your Internet Service Provider so you can access the Internet. This number may change each time you connect to the internet (“dynamic IP address”) or it may remain constant (“static IP address”). If you have an IP address, it is possible that this address could be used in combination with other information to identify you.
3.2.6 Pixel Tags
Sanofi Canada websites may also track your usage of the site through the use of pixel tags (also called clear gifs or web beacons). A pixel tag is a tiny graphic on a web page that is used to track pages viewed. Pixel tags tell the web site server information such as the IP address and browser type related to the visitor’s computer. Pixel tags may be placed in online advertisements that bring people to a Sanofi Canada website and on different pages of our sites. Web beacons provide us with information on how many times a page is opened and which information is consulted.
3.2.7 Social Plugins
This site may use social plugins (e.g., the Facebook “Like” button) to enable you to easily share information with others. When you visit our site, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you are logged into the associated social media website (e.g., Facebook) while browsing on our website, the social plugin allows that social media website to receive information that you have visited our website. The social plugin may also allow the social media website to share information about your activities on our website with other users of their social media website. For more information about the information shared via a particular social media plugin, you should refer to that social media site’s privacy statement.
3.2.8 Google Analytics and its advertising features
Among the features of Google Analytics Advertising Features, we have implemented the following features:
- Remarketing with Google Analytics to create audiences of visitors of our websites and share them with our ads accounts and offer them, as part of our campaigns on the Google Search Network and Google Display Network, relevant ads focused on the actions they took during their visits.
- Google Analytics Demographics and Interest Reporting to a) determine the distribution of the audience of our websites by age, gender and interests, b) to improve the targeting of our advertising expenses, c) to create segments for our reports, and d) to create remarketing lists.
- Integrated services that require Google Analytics to collect data for advertising purposes, including the data collect by advertising cookies and device identifiers to maximize the benefits of these products by combining them and then sharing the data in each associated account.
3.3 As the case may be, the collection of Personal Information may be governed by a disclosure document requiring your acceptance.
3.4 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.
4.1 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 user 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; and
- to allow us to assess your employment application.
4.2 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.
4.3 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.
5. Information We Share
5.1 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.
5.2 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.
5.4 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).
5.5 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.
5.6 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.
6. Records Retention
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.
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.
8. Your Rights
8.2 Sanofi Canada respects and observes the provisions set forth in the Personal Information Protection and Electronic Documents Act (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.