I. Information We Collect and How We Obtain Your Consent
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 information that could reasonably be used to contact you or to identify you personally, such as your name, email address, telephone number, mobile phone number, geographic location or mailing address (“Personal Information”). 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.
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 doctor, pharmacist, healthcare professional or caregiver (collectively, “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.
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.
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.
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
Any information you submit on the Platform may be used for a variety of purposes, including, for example:
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 a Provider on your behalf (when you have given us consent to do so);
contact you with regard to your use of the Platform;
in our discretion, to make changes to the Platform or any of our policies;
to investigate legal claims;
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 may use your Personal Information to send you relevant promotions, personalized information or updates or newsletters with information that you have requested or that may interest you.
III. 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”) to carry out your requests, respond to your inquiries or make various features of the Platform available to you. These Service Providers may help us to host or operate the Platform, analyze data, provide customer service, conduct marketing or administer surveys or questionnaires.
Business Transfers. We may share your information, including your Personal Information, with our parent company, MTPA or its subsidiaries and affiliates for internal reasons, primarily for business and operational purposes. We may share or transfer your information, including your Personal Information in connection with 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).
IV. Your Privacy Choices and Access
You may always direct 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 email@example.com; or
following the removal or unsubscribe instructions in the communication that you receive.
If you wish to verify, correct or update any of your Personal Information collected through the Platform, you may contact us at the email address or mailing address included in the Contact Us section below. In accordance with our routine record keeping, we may delete certain records that contain Personal Information that you have submitted through the Platform. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information.
V. 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.
VI. Accessing our Platform Globally – Transfer of Data
The Platform may be operated in, and in accordance with the laws of, the United States and/or Japan (the “Host Countries”). We make no representation that the Platform is governed by or operated in accordance with the laws of any other nation. If you are located in the European Union, Canada or elsewhere outside of any Host Country, please be aware that information we collect may be transferred to and processed in a Host Country. By using the Platform, or providing us with any information, you (a) acknowledge that the Platform is subject to the laws of the applicable Host Country, (b) consent to the collection, processing, maintenance and transfer of such information in and to the applicable Host Country and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.
VII. Security Measures
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 information at your own risk.
The file containing your Personal Information will be made available to the authorized employees, contractors or agents of MTPA 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. You have certain rights to access and rectify the information contained in the file held about you.
IX. Contact Us
MITSUBISHI TANABE PHARMA CANADA, Inc.
100 King Street West, Suite 5600
Effective Date: September 2018