Sandoz Canada Inc. Privacy Policy
-
Pledge on Privacy
Sandoz Canada Inc. (“Sandoz” or “we”) respects and is committed to protecting the privacy and safeguarding the personal data entrusted to us by our customers and website visitors. In processing your personal data, we pledge to fully comply with internationally recognized standards of privacy protection (more specifically the EC Directive 95/49), internal privacy guidelines and policies and applicable law.
The goal of this privacy policy (the “Policy”) is to explain how we protect your privacy and how we collect, use or disclose your personal data. By using one of Sandoz’s websites, you acknowledge that you have read and understood the Policy and consent to the collection, use and disclosure by Sandoz as set forth in this Policy. The Policy may be changed periodically. By using one of Sandoz’s websites, you acknowledge our right to change this Policy. It is your responsibility to make sure that you have read the most updated policy.
The term "personal data" as used in the Policy refers to information that can identify you as an individual such as, but not limited to, your name, birth date, e-mail address, mailing address, phone number, age and sex. Information may cease to be personal data when it is stripped of all identifiers or aggregated with personal data collected from other individuals. The next sections explain how and when we collect personal data from you.
-
Identifying Purposes of use of Personal Data
Most of our services do not require any form of registration, allowing you to visit our websites without telling us who you are. However, some services may require registration. When you register with us, you may need to complete certain fields (some are required and some are optional), as well as choose a user name and password. In these situations, if you choose to withhold any personal data requested by us, it may not be possible for you to gain access to certain parts of the websites and for us to respond to your query.
Sandoz processes personal data for specific and limited purposes which we inform you about when we ask you for information. For example, we may collect and use personal data to provide you with products or services, to bill you for products and services you request, to market products and services which we think may be of interest to you, or to communicate with you for other purposes. Information you send to our customer service department is used only for the purposes of responding to your request and is otherwise kept private. Generally, the purpose for collecting your personal data will be explained to you, in clear language, at the time of collection. If we plan to use personal data we have collected for a purpose not previously identified, we will identify and document this purpose and seek your consent before such use.
-
Consent
Your knowledge and consent are required for our collection, use or disclosure of your personal data. When you visit one of Sandoz’s websites, we may ask you for personal data. It is your choice whether or not you submit personal data to us. Generally, when you voluntarily provide us with your personal data, we will assume you consent to our collection, use and disclosure of that information for the purposes identified at the time of collection. We may assume your consent in cases where you volunteer information for an obvious purpose.
If, at any time, you decide you do not wish to receive communications or other services from us, you can let us know by contacting us using the contact information below.
Under applicable privacy legislation, there are limited circumstances where Sandoz may collect, use or disclose personal data without your knowledge and consent. For example, personal data may be collected for the purpose of responding to an emergency that threatens the life, health or security of an individual, or to comply with a subpoena, warrant or other court order.
The way in which we seek consent, including whether it is express or implied consent, may vary depending on the sensitivity of the information and the reasonable expectations of the individual. An individual may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice.
-
Non-Disclosure of Information
Sandoz will not sell, share, or otherwise distribute your personal data to third parties outside Novartis International AG or any of its subsidiaries or affiliates (collectively, the “Novartis Group”). However, personal data may occasionally be transferred to third parties who act for or on behalf of the Novartis Group, or in connection with the business of the Novartis Group, for further processing in accordance with the purpose(s) for which the data were originally collected.
Where disclosure of personal data to a third party is likely or necessary for whatever reason, Sandoz will, wherever possible, endeavor to ensure that the disclosure and intended use of the data are clearly indicated.
Such third parties may operate different privacy policies. However, we endeavor to ensure that such third parties provide the same level of protection as Sandoz and, where appropriate, we will contractually require them to process data transferred only for the purposes expressly authorized by Sandoz. Sandoz will also comply with an internal corporate guideline on the protection of personal data that flows across international borders.
We will not share with third parties any data about you that is sensitive (e.g., medical information) in the absence of your prior and explicit consent. Your consent may always be revoked at a later date. If consent is revoked Sandoz may not be able to carry out certain requests made by you. Sandoz will, where practicable, inform third parties to whom your data have been transferred of your withdrawal of consent.
-
Right of Access
You have the right to access and update your personal data or to require their deletion. You also have a right to receive a general accounting of how that information has been used and disclosed, subject to certain circumstances prescribed by law. We endeavor to ensure that personal data are up-to-date, accurate, and complete. If you wish to access or correct your personal data held by us, please e-mail our data protection officer at protection.canada@sandoz.com. Your requests will be dealt with in a prompt and proper manner. No charge will be levied for complying with a correction request, however, for all other requests Sandoz may charge a small fee to cover its costs. Requests to delete personal data will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on Sandoz.
-
Security and Confidentiality
To ensure the security and confidentiality of personal data that Sandoz collects on-line, Sandoz uses data networks protected, inter alia, by industry standard firewall and password protection. Access to personal data is restricted to those employees who have a need to use the data and who have been trained to handle such data properly and observe strict standards of confidentiality. If an employee breaches the Policy he/she will be disciplined accordingly. Staff compliance with our policies and procedures is regularly audited and reviewed. While we cannot guarantee against any loss, misuse or alteration to data, we try to prevent such unfortunate occurrences.
-
Data Transfer Abroad
The Novartis Group is a global enterprise and has databases in different jurisdictions. Sandoz may transfer your data to one of its databases outside your country of domicile. If the level of privacy protection in a country does not comply with standards substantially similar to applicable federal and provincial privacy law, we will ensure that data transfers to Novartis Group databases in that country are adequately protected.
-
Anonymous Data and "Cookies"
Most of the information that Sandoz collects from its websites is anonymous information, such as the pages you visit and searches you perform. When you visit one of our websites we do not collect any personal data from you unless otherwise authorized by you.
Anonymous information is processed by Sandoz to help improve the contents of the websites and to compile aggregate statistics about individuals using our site for internal, market research purposes. In so doing, Sandoz may install "cookies". "Cookies" by themselves cannot be used to discover the identity of the user. A "cookie" is a small piece of information which is sent to your browser and stored on your computer's hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a "cookie", this will enable you to decide if you want to accept it or not.
-
Spamming
Sandoz does not condone "spamming". Spamming is defined as sending unsolicited e-mails, usually of a commercial nature, in large numbers and repeatedly to individuals with whom the sender has had no previous contact or who have declined to receive such communications.
-
Limitation on Retention of Personal Data.
Sandoz keeps your personal data only for as long as is reasonably needed for the purposes for which such information was collected, and in accordance with any applicable legal or ethical reporting or documentation retention requirements.
-
Limitation on Use and Disclosure of Personal Data
Sandoz does not use or disclose your personal data for purposes other than those identified at the time of collection. If we want to use your personal data for purposes not identified at that time, we will obtain your consent, unless use of your personal data for the new purpose is required by law.
We do not sell, trade, or rent your personal information to others for marketing purposes.
We may share your personal data with third-party agents and contractors hired to perform certain services on our behalf, such as fulfillment services, technical support, delivery services, and financial institutions.
Applicable privacy laws in Canada permit or require the disclosure of personal data without consent in limited circumstances. Where permitted or required by applicable laws, Sandoz may disclose your personal data.
We use physical, administrative and technical safeguards, appropriate to the sensitivity of the information, to protect your personal data against loss, theft, misuse, unauthorized access, disclosure, copying and alteration. Although we attempt to safeguard personal data, we cannot guarantee it is completely secure from individuals who might attempt to deliberately evade security measures or intercept transmissions over the Internet.
-
Personal Information and Children
Sandoz will not knowingly collect, use or disclose personal data from a minor under the age of 14, without obtaining prior consent from a person with parental responsibility (e.g., a parent or guardian) through direct off-line contact. We will provide the parent with (i) notice of the specific types of personal data being collected from the minor, and (ii) the opportunity to object to any further collection, use, or storage of such information.
-
Links to Other Sites
This Policy applies only to Sandoz websites to the exclusion of third party websites. Sandoz may provide links to other websites which we believe may be of interest to our visitors. We aim to ensure that such websites are of the highest standard. However, due to the nature of the World Wide Web, Sandoz cannot guarantee the standards of every website link it provides or be responsible for the contents of non-Sandoz sites.
-
Accountability and Contacting Sandoz/Challenging Compliance
If you have a question or concern about any collection, use or disclosure of personal data by Sandoz or about a request for access to your own personal data, please contact Sandoz’s data protection officer at protection.canada@sandoz.com. The data protection officer is responsible for Sandoz's compliance with applicable privacy legislation and the Policy. Sandoz has procedures in place to implement the Policy, including procedures for receiving and responding to complaints and inquiries, and programs to educate our staff about their responsibilities under applicable privacy legislation and the Policy.
We will use reasonable efforts to respond promptly. Except where required by law, Sandoz cannot ensure a response to questions or comments regarding topics unrelated to this Policy or Sandoz's privacy practices. If any inquiry or complaint is not resolved to your complete satisfaction, you may contact the applicable government privacy commissioner.
We aim to constantly improve the tools available to you to manage the personal data that you provide to us. Please refer to this page from time to time to review these and other new features.
