Privacy Policy
This Privacy Policy explains the privacy practices governing information collected through your interactions with us, including the websites and mobile applications (collectively referred to herein as the “Platform” or “Platforms”) owned, operated or controlled by MITSUBISHI TANABE PHARMA CANADA, Inc. (“MITSUBISHI TANABE PHARMA CANADA,” “we,” “our” or “us”), a subsidiary of Mitsubishi Tanabe Pharma America, Inc. (“MTPA”).
Please read this Privacy Policy carefully, because when you submit information to or through the Platforms, you are consenting to the collection, processing and retention of your information as described in this Privacy Policy. We will always collect your Personal Information by fair and lawful means (for example, when you register with us). We may collect Personal Information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law.
I. Personal Information We Collect
“Personal Information” means information about an identifiable individual as described under Canadian privacy laws. Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work email address.
We may collect different types of Personal Information about you, depending on our relationship with you. Generally, we collect the following types of Personal Information through the following means (not all of which may apply to you).
Personal Information You Provide to Us.
When you use the Platform, for example, to register to create an account, we or our service providers may collect the contact information that you provide to us, such as your name, email address, telephone number, mobile phone number, geographic location or mailing address. If you choose to use Touch ID to verify your account, we may also collect your fingerprint scans. You may also choose to provide us with Personal Information about your health or medical status, when you enroll in our patient support programs.
Information We Collect Automatically.
Whenever you visit or interact with the Platform, we may use a variety of technologies that automatically or passively collect information about how you access or use the Platform (“Usage Information”). Usage Information may include your browser type, operating system, the page served, the time and the preceding page views. However, this information does not identify you as an individual user. We do not treat Usage Information as Personal Information unless it is combined with other data that, once linked, can be used to identify you.
Device Identifiers.
MITSUBISHI TANABE PHARMA CANADA may also automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Platform. A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Platform, help diagnose problems with our servers, analyze trends, track users’ web page movements and help identify and gather broad demographic information for aggregate use.
Cookies and Do Not Track.
We may collect information about you or your use of the Platforms through cookies, tracking pixels, mobile identifiers or other technologies. We use this information to better understand, customize and improve the Platforms, services and offerings, as well as to manage our advertising. The information we collect through cookies, tracking pixels or mobile identifiers may help us understand how visitors use and engage with the Platforms. If you have provided us with your Personal Information, for example, when you registered for an account or requested information from us, we may associate this Personal Information with information we have collected through cookies, tracking pixels, mobile identifiers or other technologies. We will provide you with notice or obtain your express consent before using certain advertising and analytics cookies.
Cookies.
A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Platforms. When you use the Platforms, neither we nor any third parties collect Personal Information about your online activities, over time or across third-party websites. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.
Tracking Pixels.
A “tracking pixel” also known as an Internet tag, pixel tag, web beacon or clear GIF, links web pages to web servers and their cookies, and may be used to transmit information collected through cookies back to a web server.
Google Analytics.
We use tools like Google Analytics to measure traffic to the Platform and how users interact with the Platform. You can opt out of Google Analytics by downloading and utilizing the Google Analytics Opt-out Browser Add-on. At various times, we may also use other tools to measure the efficacy of our marketing campaigns.
Mobile Identifiers.
We may use software development kits (“SDKs”) or mobile advertising identifiers (for example, “IDFA” on Apple mobile devices or “Advertising ID” on Android mobile devices), which function similarly to cookies on mobile devices. You may reset your IDFA or Advertising ID in the settings on your mobile device.
Do Not Track.
Currently, the Platform is not designed to respond to “Do Not Track” signals sent from your browser. For more information about “Do Not Track,” please visit www.allaboutdnt.org.
II. How We Use Your Information
We may use your Personal Information for a variety of purposes, including, for example, to:
- respond to your questions and requests;
- provide you with access to certain features of the Platform;
- determine eligibility for, and for ongoing administration of, patient support programs related to pharmaceutical products;
- verify your identity;
- improve the Platform;
- communicate with you;
- contact your doctor, pharmacist, healthcare professional or caregiver (collectively, “Providers”) on your behalf (when you have given us express consent to do so);
- contact you with regard to your use of the Platform;
- send you relevant promotions, personalized information or updates or newsletters with information that you have requested or that may interest you;
- in our discretion, to make changes to the Platform or any of our policies;
- investigate legal claims;
- report adverse events as required by applicable law;
- such purposes for which we may obtain consent from time to time; and
- such other uses as may be permitted or required by applicable law.
We will only use the information you provide to us in a manner that is consistent with this Privacy Policy or where we have otherwise obtained your consent.
III. Your Consent
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances.
You may decide to provide us with another person’s email address or phone number so that person may be provided with information about the Platform or our products, or so that we may facilitate your communication with other people through the Platforms. You may also provide us with access to your address book if you use our app to facilitate these connections. Your contacts will be provided with the option not to receive further communications from MITSUBISHI TANABE PHARMA CANADA.
If you are a Providers, you are responsible for obtaining any legally required authorization, consent or other permission from your patients prior to providing their Personal Information to us through the Platform. By submitting any Personal Information about a patient, you represent and warrant to us that you have obtained all required permissions to do so.
IV. How We May Share Your Information
Service Providers.
We may share your Personal Information with third parties that perform functions on our behalf (“Service Providers”). For example, we may rely on Service Providers to help us to host or operate the Platform, analyze data, provide customer service, conduct marketing or administer surveys or questionnaires. If we transfer your Personal Information to a Service Provider, we require that they maintain the confidentiality of your Personal Information and keep it secure. We also require that our Service Providers comply with applicable privacy laws and only use your Personal Information for the limited purposes for which it is provided.
Affiliates.
We may share your Personal Information with our parent company, MTPA, or its subsidiaries and affiliates for internal business and operational purposes. In some cases, these affiliates may act as our Service Providers and perform functions on our behalf.
Business Transactions.
We may disclose your Personal Information in connection with a business transaction, such as a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by MITSUBISHI TANABE PHARMA CANADA or any affiliated company (in each case, whether in whole or in part).
Legal Disclosure.
We may disclose your Personal Information to third parties to comply with a legal obligation, when we believe in good faith that the law requires it, at the request of governmental authorities conducting an investigation, to verify or enforce our Terms of Use or other applicable policies, to respond to an emergency or otherwise to protect the rights, property, safety, or security of MITSUBISHI TANABE PHARMA CANADA, third parties, visitors to the Platform or the public.
V. Your Privacy Choices and Rights
You may withdraw your consent to our collection, use or disclosure of your Personal Information, for example by directing us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, or not to send you newsletters, updates, emails or other communications by:
- sending us an email at contact@mtpharma-ca.com; or
- following the removal or unsubscribe instructions in the communication that you receive.
We will accommodate your request to withdraw consent, subject to legal or contractual restrictions. Withdrawal of your consent may mean that we will no longer be able to provide you with certain products or services. Please note that if you opt out from receiving marketing-related emails, we may still need to send you communications about your participation in our programs, or other matters.
You may make a request to review any Personal Information about you that we have collected, used, or disclosed, and we will provide you with any such Personal Information to the extent required by applicable laws. Upon request, and to the extent required by law, we will also provide you with details about categories of persons who have access to your Personal Information within MITSUBISHI TANABE PHARMA CANADA and the duration of time your Personal Information will be retained.
You may also challenge the accuracy or completeness of your Personal Information in our records. If you demonstrate that your Personal Information in our records is inaccurate, incomplete or equivocal, or that the collection, use or disclosure of your Personal Information is not authorized by law, we will amend or delete your Personal Information as required. Where appropriate, we will transmit the amended information to third parties to whom we have disclosed your Personal Information.
Before processing a request for access to or correction or deletion of your Personal Information, we may require that you provide certain information to confirm your identity to our satisfaction and fulfil your request. We will not charge you any fees in connection with your request without first providing you with an estimate of the approximate fees, if any.
If you object to how we handle your request, you may have the right to make a complaint to the Privacy Commissioner of Canada or the applicable provincial privacy commissioner.
VI. Links to Other Websites
The Platform may contain links to other sites, maintained by third parties. These links are provided only as a convenience to you. MITSUBISHI TANABE PHARMA CANADA, MTPA, its subsidiaries and affiliated companies have no control over, and are not responsible for any content, products or services offered by or found on third-party sites, or their Privacy Policies. Links to third-party sites do not constitute an assumption of liability for or sponsorship, endorsement or approval of these sites or the content contained on these sites.
VII. International Transfer of Personal Information
Personal Information we collect may be transferred to and processed by us and our Service Providers outside your jurisdiction of residence – specifically, at locations in Canada, the United States and/or Japan. While your Personal Information is in a jurisdiction outside of your jurisdiction of residence, it is subject to the laws of that other jurisdiction, which may have different data protection laws than your jurisdiction of residence. Those laws may require disclosure of your Personal Information to government authorities of that other jurisdiction. For more information about our policies and practices regarding the international processing of Personal Information, please contact us using the contact information below.
VIII. Security Measures and Retention of Personal Information
We use certain reasonable security measures to help protect your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platform and provide us with your Personal Information at your own risk. The file containing your Personal Information will be made available to the authorized employees, contractors or agents of MITSUBISHI TANABE PHARMA CANADA who need to access the information in connection with the purposes for which it was collected. Such Personal Information will be held primarily in an electronic database.
We will retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, and as permitted or required by law. In accordance with our routine record keeping, we delete records that contain Personal Information that you have submitted through the Platform.
IX. Changes to This Privacy Policy
We may update and post revisions to this Privacy Policy from time to time. If our Privacy Policy changes in a way that significantly affects how we handle your Personal Information, we will not use the Personal Information we currently maintain without providing you notice or obtaining your consent, where appropriate. We encourage you to periodically review this page for the latest information about our privacy practices.
X. Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us by email at contact@mt-pharma-us.com or write us at:
MITSUBISHI TANABE PHARMA CANADA, Inc.
100 King Street West, Suite 5600
Toronto, Ontario M5X 1C9
Effective Date: June 2024
