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Privacy Policy

Date of Implementation: December 1, 2022

Date of Last Revision: December 1, 2022

1.0 Introduction

In the course of the operation of this website (www.myopioidcme.ca), supported by the Coalition sponsors: Ethypharm Inc., Mallinckrodt Canada ULC, Paladin Labs Inc. and Purdue Pharma Canada (“the Coalition Sponsors,” “us,” “we”), and as permitted or required by Canadian law. This Privacy Policy describes our practices in relation to the personal information we may collect, use and disclose about the registrants for this website. To ensure that such personal information is appropriately and respectfully managed in compliance with applicable privacy laws of Canada and its various provinces (“Canadian Law”). 

Personal information means any information or piece of information which could identify you either directly (e.g. your name, email address, telephone number) or indirectly (e.g. a unique identification number).

 2.0 Scope of Policy

This Privacy Policy describes how personal information will be collected, used and disclosed through the use of this website operated by MRM/McCann (“the website administrator”). This website is intended for use by Canadian healthcare professionals only.

The Coalition sponsors take the privacy of your personal information seriously.  In the event that you send us any of your personal information, we are committed to collecting, maintaining, and securing your personal information in accordance with Canadian Law and our internal data protection policies.

This Privacy Policy describes how we process your personal information when you use this website, or otherwise provide personal information to us through the means described in this Privacy Policy.

Please note this Privacy Policy does not cover any third-party sites referred to or accessed using links or buttons on this Site. These third-party sites have their own terms and conditions of use and privacy policies.  We are not responsible for the terms and conditions, privacy policies or content of any website referred to or accessed through this website.

3.0 Accountability

The website administrator is responsible for compliance with the Policy.

4.0 Collection of Personal information

We may collect the following personal information about you:

  • Contact details such as your name, professional title, email address, address, phone number;
  • Information about your visits to our website, including the type of browser and operating system that you use, access times, pages viewed, URLs clicked on, your IP address, and login credentials;
  • Device information, such as your IP address, device ID, device attributes and location information.

We collect personal information directly from you when you register for the website, use the website or when you communicate with us.

Certain information, some which are considered as personal information may be recorded automatically during your visit to this website such as, including but not limited to, your IP address, internet address from which you are connected, language preference, the date and time of the visit and the pages visited, the operating system, the browser software and “cookies” that determine how access is performed, when and in what numbers.

Information is collected to administer the website, including to:

  • authenticate users of the website;
  • maintain, evaluate, optimize, secure and improve the website;
  • provide links to accredited opioid continuing educational materials;
  • compile statistics of interest to create metrics reports as part of the Health Canada mandated Risk Management Plan commitments; and,
  • comply with our obligations, including but not limited to legal, regulatory and operational obligations.

We may use a website notification list obtained from a third party, which includes deidentified demographic information.

5.0 Consent

The form of consent may vary depending on the circumstances and the type of personal information being requested. Consent can be express (express consent may be oral, in writing or electronic), or implied (such as when you provide your name and address in order for us to contact you).

When determining the appropriate form of consent, we take into account the sensitivity of the personal information, the reasons we are collecting it, and the reasonable expectations of the person giving the consent. We only collect personal information about you when you voluntarily provide it to us by using our website or by voluntarily disclosing your personal information to us.

Whenever you submit personal information, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.  If you do not agree to the collection, use or disclosure of your personal information in accordance with this Privacy Policy, please do not submit your personal information.

In some cases, we may passively collect personal information through your use of our website. For example, your IP address or cookie may contain information that could make you identifiable. In such a case, your use of our website without changing your browser settings constitutes your implied consent to the collection of that personal information. However, we will not use your information for purposes other than those identified in this Privacy Policy.

In certain circumstances, as permitted or required by Canadian Law, we may collect, use or disclose your personal information without your knowledge or consent. These circumstances include, but are not limited to, the following: (i) information that is publicly available, (ii) where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way, (iii) to investigate a breach of an agreement or a contravention of law, (iv) for the purposes of detecting, suppressing or preventing fraud, (v) to act in response to an emergency that threatens the life, health or security of an individual, or (vi) to comply with a subpoena, court order or warrant.

6.0 Consent Withdrawal

You may delete your account at any time. If you withdraw your consent, we will delete your personal information in a timely manner except as required by law. However, withdrawing your consent may impair your ability to access certain information or this website.

In some cases, we are obliged to keep your personal information to comply with legal requirements and statutory retention periods. In such a case, we will ensure that your personal information will only be used to comply with those obligations and not for other purposes.

 7.0 Cookies and other technologies

Our websites may use cookies and other similar technologies. A cookie is a small text file sent to your computer when you visit a website. Cookies perform various tasks, such as letting you navigate between pages efficiently, storing your preferences and generally improving your experience of our website.

If you do not want cookies (or certain types of cookies) enabled on your computer or other device, you can deactivate them in your browser settings. However, deactivating cookies may affect the usability and functionality of the website.

8.0 Analytics

In order to adapt the website to the demands of its visitors, we measure the number of visits to the website.

9.0 Where we send your personal information

The website administrator stores personal information in Ontario, Canada, regardless of where it collects the information. 

10.0 Who we share your personal information with

Your personal information is not shared with anyone. However, general metric summary reports, such as links accessed and visits to the Website, will be shared with a coalition of opioid sponsors and regulatory authorities to assess the effectiveness of this educational Website.

11.0 How long will your personal information be retained

Personal information obtained from the operation of this website will be stored in accordance with Canadian Pharmacovigilance regulation requirements (https://www.canada.ca/content/dam/hc-sc/migration/hc-sc/dhp-mps/alt_formats/pdf/compli-conform/gmp-bpf/docs/gui-0102_gvp-eng.pdf), please refer to the Maintenance of records section.

We will only keep your personal information for the period required by law and where we need to do so in connection with any legal action or an investigation.

12.0 What rights you have over your personal information

You have the following rights:

  • To ask about the processing of your personal information;
  • To request a copy of your personal information, its correction and/or deletion;
  • If you have provided consent for us to process your personal information, you may withdraw it with limited exceptions. The withdrawal of consent shall not affect any processing based on consent before its withdrawal;
  • In certain cases you can request a restriction on the processing of your personal information, for example where your wish to verify the accuracy of your personal information or where you object to the processing.

If you would like to exercise any of these rights, you can get in touch by using the contact information in the last section of this Privacy Policy.

13.0 How We Protect Your Data

You are responsible for maintaining the security of your account credentials and other authentication involved in obtaining access to password-protected or secure areas of this website.  This website will treat access to the website through your account credentials as authorized by you.

We store and retain information for as long as necessary to fulfill the purposes for which you provided the information, to comply with requirements and statutory retention periods. In such a case, we will ensure that your personal information will only be used to comply with those obligations and not for other purposes.   We are committed to collecting, maintaining, and securing your personal information in accordance with Canadian Law and our internal data protection policies.

14.0 What Data Breach Procedures We Have In Place

No method of transmission over the internet, or method of electronic storage, is fully secure. While this website implements appropriate technical and organizational security measures to protect your personal information from unauthorized access, use, or disclosure, due to the public nature of the internet, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information, we will notify you electronically, or in writing, if permitted to do so by law, as applicable.

15.0 What Third Parties We Receive Data From

This website does not request nor receive data from other websites. The website does provide links to third party accredited Continuing Education programs and screening tools. We are not responsible for the personal information you provide to the third parties.

16.0 What Automated Decision Making And/Or Profiling We Do With User Data

When you access this website, we collect information about how you accessed the website and your use of the website.  A server log is a list of the activities that a server performs. The website server automatically collects and stores in server logs your search queries, Internet Protocol (IP) address, hardware settings, browser type, browser language, the date and time of your request and referral URL and certain cookies that identify your browser or account.  No automated decision-making or profiling is done.

17.0 Industry Regulatory Disclosure Requirements

The www.myopioidcme.ca website is operated and administered by MRM/McCann on behalf of the Coalition sponsors, from within the Province of Ontario, Canada.  This Privacy Policy will be interpreted and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable in Ontario (other than any conflict of laws rules that would result in the choice of laws of another jurisdiction) and you agree to submit to the exclusive jurisdiction of the courts of Ontario in connection with any matter arising out of or relating to the website or your use of the website.

18.0 Changes to this Privacy Policy

The Coalition sponsors may update the Policy from time to time to reflect a change in its practices or Canadian Law. The date of the most recent revision will be posted at the top of the Policy and we ask that you review the Policy to see if it has been revised since the last time you communicated with us. Your continued use of the website or disclosure to us of your personal information after the Policy has been revised will signify your acceptance of the revised terms of the Policy.

19.0 Contact Us for Privacy Policy Issues

If you have questions about how we use your personal information, please contact us at info@myopioidcme.ca