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Privacy Policy

Privacy Policy of SpotMe

Introduction

If you are viewing this page, you may have been using one of our Services, and you may want to find out more about the Data processing carried out during the use of our Services. SpotMe takes care of protecting the confidentiality of the information you share, and commits itself to the strictest compliance with the data protection law that applies.
This document is aimed at providing all users with an outline of what the Services provided by SpotMe consists of, what Personal Data are collected via the Services and how such Data are processed.
SpotMe provides the Services to Clients who shall use it for the purposes and according to the modalities described in their privacy policy. In case of any inconsistency or discrepancy between the present document and the Client privacy policy, this latter document shall prevail.
The contractual relationship between SpotMe and the Client is specifically addressed in the related paragraphs of the present document.

Service provided by SpotMe

SpotMe is a company specialized in providing mobile event and engagement application solutions that may either be built autonomously by Clients or with the assistance of a SpotMe trained team of specialists. Each of these applications provide End-Users with a mobile and digital solution to interact and communicate during events, meetings or community engagements. Such communication is carried out in a paperless environment through the functionalities available in the application. Once the End-User has joined the event environment, they can start using the engagement features of the SpotMe app, including but not limited to, posting questions, receiving learning or training material, communicating in real time with other End-Users, taking notes, casting votes etc., the exact functionalities depending on the feature set made available on that application and on the setting thereof, as established by the Client.

Types of Data collected

Usage Data

The use of and navigation through the Services (as well as the use of any third party’s application embedded and/or available therein), implies the communication of Usage Data, which is implicitly acquired during the navigation of the End-User or Administrative User through the internet communications protocol.

Usage Data includes but is not limited to, the IP addresses or domain names of the devices utilized by the End-Users or Administrative Users, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the End-User or Administrative User, the various time details per visit (e.g., the time spent on each page within the SpotMe Solution) and the details about the path followed within the SpotMe Solution with special reference to the sequence of pages visited, and other parameters about the device’s operating system and/or the End-User’s or Administrative User’s IT environment.

Usage Data is not collected for the purpose of identifying the End-User or Administrative User. However, all users must be aware that the identification may be possible through further elaborations and associations, as well as with information held by third parties.

Should any willful act of misconduct, fraud or criminal offence be perpetrated, Usage Data could potentially be used for ascertaining individual responsibilities.

Data communicated by End-User and Administrative User

To use the Services, End-Users and Administrative Users may need to register and disclose the information requested in the relevant forms in a complete and truthful manner. Whenever a field in the forms provided is described as “optional” or “not compulsory” or is not marked with “*” symbol it means that the End-User or Administrative User is free not to communicate the requested Data and that their request can be fulfilled notwithstanding the absence of this information. The Data collected by the SpotMe App or Backstage for registration purposes are: email address, first name, last name, password. End-User’s and Administrative User’s Personal Data shall be processed upon their prior, free and informed consent, when required by the law, and solely for the purposes outlined in the present privacy policy. End-Users and Administrative Users are responsible for any third party Personal Data obtained, published or shared through using thе SpotMe Services and confirm that they have the third party’s consent to provide the Data to the Client and / or SpotMe.

Mode and place of processing the Data

Methods of processing

The Data of End-Users and Administrative Users is processed in an appropriate manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

Place

The Data is processed at the Client’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact SpotMe privacy@spotme.com.

Retention time

The Data is kept for the time necessary to provide the Services requested by the End-User or Administrative User, or stated by the purposes outlined in this document, and the End-User or Administrative User can always request that the Client suspend or remove the Data. For further information, please contact SpotMe at privacy@spotme.com.

Purposes of processing

The Data concerning the End-User and Administrative Users is collected for the purposes described below.

In particular, Usage Data is solely processed to:

  • Permit the navigation of End-Users and Administrative Users through and the use of SpotMe Services from an operational and technical point of view;
  • Improve the End-User’s and Administrative User’s navigation experience within the SpotMe Solution;
  • Carry out statistical analysis in an anonymous and aggregated fashion;
  • Ensure the security of Data and of the SpotMe Solution.

As for the Data communicated by End-User or Administrative User on a voluntary basis, it is processed for the following purposes:

  • To provide the Services;
  • To fulfil specific End-User’s or Administrative User’s requests including, but not limited to, contact or assistance requests, etc.;
  • To fulfil duties which lie with the Client as set forth in the applicable laws and regulations;
  • To allow End-User’s or Administrative User’s registration and the access to the personal area available in the SpotMe Solution;
  • To send informational messages and reminders related to the SpotMe App and Backstage to End-Users or Administrative Users, where applicable;
  • To send advertising and information messages aimed at promoting the Client’s Service, upon End-User’s or Administrative User’s consent;
  • Where applicable, to allow third parties involved in the provision of the Services to fulfil their contractual obligations.

Further details about the processing of Personal Data carried out when using the Services can be found in the section below.

How it works for End-Users

End-Users must be aware that other users of the SpotMe App might have access to, or re-post, or otherwise share what they have published, which could also include Personal Data such as name, nickname/screen name, location and other information about the End-User, as well as information about the event they are participating to. These other users might make such information publicly available. Also, End-Users must be aware that the SpotMe App allows interactions among mobile devices running the SpotMe App or between mobile devices running the SpotMe App and other components of the SpotMe App. In particular, at each event at which the SpotMe App is employed, the Event Organizer determines the rules as to how individually-identifiable information in the SpotMe App will be made accessible to other End-Users. Where applicable and once these rules have been determined, SpotMe enforces them, including by withholding Data from the Event Organizer where that Data was gathered under a commitment of anonymity.

Some of the ways in which individually-identifiable information about a participant are made available to others vary from event to event including, but not limited to the following:

  • An End-User’s contact and other profile information may be provided to other attendees or exhibitors when the End-User has instructed SpotMe to send that information, e.g. through a business card exchange carried out through the SpotMe App;
  • Session attendance Data may be provided to the Event Organizer or the sponsor of the session when the End-User has checked into a specific session or has been checked into a specific session;
  • Poll/survey Data may be provided to the Event Organizer or the sponsor of the poll/survey;
  • Winners of SpotMe App networking games or challenges managed through the SpotMe App may be announced or made visible on a display.

End-Users who are not comfortable with the functioning of the SpotMe App may return their SpotMe device at any time (if they have been provided with such a device), may delete the SpotMe App from their personal mobile device or may request the deletion of their Personal Data to the Event Organizer.

How it works for Administrative Users

Administrative Users must be aware that their data will not be shared with others, unless they are also listed as Administrative Users by the Client under the same organization in Backstage. In this case, the data that will be visible for all Administrative Users under one organization are their names.

Data communicated to SpotMe

Data automatically collected by SpotMe

The SpotMe Solution usually provides for a closed environment, meaning that the End-User must be authenticated with an email link or a similar authentication scheme before joining the SpotMe App, and the Administrative User by authenticating with email and password before joining Backstage. If no authentication scheme is available, End-Users can access the SpotMe App by providing the following Data: email address, first name and last name. SpotMe does not automatically collect, via the service, any personal identifiable information from the End-Users. Nonetheless, the use of the Services may imply the automatic collection of some End-User’s information and other Usage Data, including but not limited to, IP address, operating system and type of browser used by End-User’s mobile device.

Communication of Data to SpotMe by the Client

Notwithstanding the above, under specific circumstances and, namely, as part of the functioning of the SpotMe Solution related to a meeting or event at which the SpotMe App is employed, SpotMe may receive some personal identifiable information about the End-Users and Administrative Users, including but not limited to, their name, surname and email address, in order to enable the particular features of the SpotMe Solution.

SpotMe does not own any such Data and shall process them, as Data Processor, according to the instructions and the terms and conditions set forth in the agreement entered into with the Client who remains the sole Data Controller.

Data transfers

Liability for Data transfers

Clients are solely liable for the lawful transmission of Personal Data referring to End-Users and Administrative Users to SpotMe. Clients shall inform such Data Subjects accurately about the intended data transfer and collect their prior explicit consent, if needed. In particular, Clients shall inform their users about profiling activities possibly performed through recourse to services provided by SpotMe. In case such profiling activities take place, Clients are solely liable for the fulfilment of the notification, if required, to the competent Data Protection Authority, as well as to comply with any requirements prescribed by the applicable privacy laws which are relevant to the aforesaid data processing activities.
Therefore, Clients are bound to inform the End-Users and Administrative Users correctly about the data treatment performed with recourse to services provided by SpotMe according to applicable law, i.e. providing a privacy policy including information about data treatment performed by SpotMe on their behalf.

To the same extent, Clients are solely liable for the enforcement of consent revocations or other requests received by Data Subjects. Clients shall inform SpotMe accurately and without undue delay about the revocation of consent or the request and about the Data to be deleted, amended, rectified etc. Clients are solely liable for any damage possibly arising to third parties (e.g. their users or other Users) due to an unlawful processing of Personal Data transferred to SpotMe.

Data transfer abroad – European/Swiss Users’ rights

SpotMe operates through a network of subsidiaries.

As for the transfer of Personal Data to countries outside of the European Union, European Users must be aware of the following:

Data transfer to Switzerland

European Users must be aware that such transfer is lawfully carried out pursuant to the European Commission’s decision 2000/518/EC of 26 July 2000 on the adequate protection of Personal Data provided in Switzerland.

Data transfer to the US

SpotMe, Inc. participates in and complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union to the United States. SpotMe Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
If there is any conflict between the terms in this document and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view SpotMe Inc.’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce here https://www.privacyshield.gov/list).

Following the decision of the Court of Justice of the EU on Case C-311/18 adopted on July 16, 2020 pursuant to which Commission Implementing Decision (EU) 2016/1250 on the adequacy of the protection provided by the EU-U.S. Privacy Shield is declared invalid, transfers of Personal Data to the US, including but not limited to SpotMe intra-group transfers, are subject to Standard Contractual Clauses (SCCs) for the transfer of personal data to processors established in third countries which do not ensure an adequate level of data protection. European Users must be aware that such transfer is lawfully carried out pursuant to Commission Decision 2010/87/EU on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council.

Notice to Swiss End-Users – Data transfer from Switzerland to the US

SpotMe, Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. SpotMe, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
SpotMe Inc. is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from Swiss individuals and commits to subject the processed Personal Data to the Privacy Shield Principles. This, most importantly, includes the right of individuals to access their personal data processed by SpotMe Inc. SpotMe Inc. also complies with the Privacy Shield Principles for all onward transfers of Personal Data from Switzerland, which means that it remains liable in cases of onward transfers to third parties. With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, SpotMe Inc. is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this document. SpotMe Inc. is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute resolution under the Privacy Shield

In compliance with the Privacy Shield Principles, SpotMe Inc. commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact SpotMe Inc. at privacy@spotme.com, referring to ”Privacy Shield” and expect the complaint to be dealt with within 45 days. In case of failure by SpotMe Inc. to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.
In this regard, SpotMe Inc. has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact SpotMe Inc. at privacy@spotme.com, in order to be directed to the relevant DPA contacts. Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Swiss Users must be aware of the fact that the Federal Data Protection and Information Commissioner (FDPIC) can act as a mediator in all disputes related to the Swiss Users’ Data protection. Therefore, Swiss Users can submit any Data protection related dispute to the mediation of the FDPIC.

Choice

All Users have the right to choose (opt out) whether their personal data is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by them. If a User wishes to opt out, all they need to do is contact SpotMe at privacy@spotme.com. Applicable law allows certain exceptions to User’s ability to opt out, such as where it is party to a contract with SpotMe that is still being performed, where law requires SpotMe to maintain information for warranty claims, or otherwise. Where applicable law permits SpotMe to retain and continue to use such information, SpotMe will do so only to the extent permitted or required by law.

By derogation to the previous paragraph, it is not necessary to provide choice when disclosure is made to a third party that is acting as SpotMe’s agent (such as SpotMe’s service providers who perform services that help the company run its business). However, SpotMe shall always enter into a contract with the agent.

For sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual), SpotMe must and shall obtain affirmative express consent (opt in) from Users if such information is to be (i) disclosed to a third party or (ii) used for a purpose other than those for which it was originally collected or subsequently authorized by the Users through the exercise of opt-in choice. In addition, SpotMe should treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.

Detailed information on the processing of Personal Data

Given the information above, Personal Data can be collected by using some of the following services:

Unique device identification

SpotMe may associate a randomly generated identification code to the User’s device. Such codes shall be used exclusively for statistical purposes and any such statistics shall be carried out in aggregate and anonymous fashion. For further information, the User can contact the Owner at the contact details provided in the present document.

Hosting and backend infrastructure

This type of service has the purpose of hosting data and files that enable the SpotMe App to be run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of SpotMe App. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Push notifications

SpotMe may send push notifications to the User.

Cookie Policy

SpotMe uses Cookies. To learn more and for a detailed cookie notice, you may consult the Cookie Policy on http://spotme.com/specifications.

Additional information about Data collection and processing

Legal action

The Data Subjects’ Personal Data may be used for legal purposes by the Client, in Court or in the stages leading to possible legal action arising from improper use of the SpotMe Services. The Data Subject declares to be aware that the Client may be required to reveal Personal Data upon request of public authorities.

Additional information about Data Subject’s Personal Data

In addition to the information contained in this privacy policy, SpotMe may provide the Data Subject with additional and specific information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, the SpotMe Solution, or where applicable, third party services may collect files that record interaction with the SpotMe App or Backstage (System logs) or use for this purpose other Personal Data (such as IP Address).

Children Under the Age of 13

The Service is directed to the general public. Client and SpotMe do not knowingly collect information from children under 13 years of age or have any reasonable grounds for believing that children under the age of 13 are accessing the Service. If Client or SpotMe learn that they have inadvertently collected Personal Data from a child under age 13, that Data will be deleted as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us at privacy@spotme.com.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from SpotMe at any time at privacy@spotme.com.

The rights of Data Subjects

Data Subjects have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller or SpotMe to learn about their contents and origin, to access, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons or to request data portability. Requests should be sent to the Data Controller (the Client) at the contact information provided in its privacy policy or to SpotMe at privacy@spotme.com. Data Subjects can lodge a complaint with the competent supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement of GDPR in relation to the processing of their Personal Data.

In the case of a personal data breach of data where SpotMe is the data processor, but not data controller, SpotMe will notify the Data Controller without undue delay after becoming aware of a personal data breach. In the case of a personal data breach of data where SpotMe is the data controller, SpotMe will without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55 GDPR, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. If the notification to the supervisory authority is not made within 72 hours, it will be accompanied by reasons for the delay. In the data breach notification, SpotMe will describe the nature of the personal data breach including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned, and communicate the name and contact details of the data protection officer or other contact point where more information can be obtained and describe the likely consequences of the personal data breach; describe the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects. SpotMe will document any personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken.

Questions on data protection and contact / information, correction, deletion and blocking

You are always entitled to request information about any of your data that SpotMe has stored, as well as their origin and recipient and the purpose it was stored for. If you have any questions about data protection or if you wish to access, request data portability, correct, block or delete your profile or any of your personal data, or if you would like, at any time, to revoke a granted authorization regarding the use of your customer data or e-mail address, you can do so either directly via the SpotMe App, depending on the its version or contact the following: SpotMe Holding SA, Avenue du Théâtre 1, 4th floor, 1005 Lausanne, Switzerland or by email privacy@spotme.com. SpotMe external data protection officer is Dr. Christian Rauda (board-certified attorney for information technology law), GRAEF Rechtsanwälte, Hamburg, Germany. You can reach him via privacy@spotme.com.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its End-Users and Administrative Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If an End-User or Administrative User objects to any of the changes to the Policy, they must cease using SpotMe Solution and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about End-Users and Administrative Users.

Additional information about Data collection and processing

For any further information about the Data processing by SpotMe as regards the provision of the Service, Users can write an email to the following address privacy@spotme.com.

Definitions and legal references

Administrative User” is an individual who is assigned and authorized by the Client to access and manage the functionalities of SpotMe Apps via Backstage.

Backstage” is the web-based Content Management System service for the management of applications (apps) including their design and content.

Client” means the natural or legal person who has purchased SpotMe services for its professional, commercial or entrepreneurial purposes and has thus access to the Service.

Cookies” means a small piece of data stored in the User’s device.

Data Controller (or Owner)” means the natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of SpotMe App. The Data Controller of the SpotMe App, unless otherwise specified, is the Client.

Data Processor (or Data Supervisor)” means the natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Subject” means the legal or natural person to whom the Personal Data refers. End-User (or User) means The individual using the SpotMe App, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

End-User” (also “Participant User”, or “User”, or “App User”) means the individual using the SpotMe App or any other of the SpotMe Services.

Event Organizer” means any User who has been granted permission by the Client to define the functionalities and permissions of the SpotMe App during an event or a community engagement where the SpotMe App is used.

Personal Data (or Data)” means any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Services” means the services, such as access to software, content, platform, infrastructure, and storage space, that are provided to Client and made available online by SpotMe, including associated SpotMe offline or mobile components and which may entail the processing of End-Users’ Data. Using SpotMe Services means granting access and enabling use of the entire SpotMe solution, composed of Backstage, SpotMe app (application) and SpotMe Cloud.

SpotMe App” means the hardware or software tool and/or platform based on the Service by which the Personal Data of the User is collected.

SpotMe” means the company SpotMe Holding SA with registered office at Avenue du Théâtre 1, 4th floor, 1005 Lausanne, Switzerland and including its subsidiaries SpotMe SA, SpotMe Inc., and SpotMe Pte. Ltd.

Usage Data” means information collected automatically from the SpotMe App or Backstage (or third party services employed in SpotMe), including but not limited to, the IP addresses or domain names of the computers utilized by the Users who use SpotMe, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.


Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, Art. 13 and Art. 14 of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to SpotMe.

Privacy Policy of Novartis

Website Privacy Policy
Effective: August 31, 2018

This Privacy Statement describes the ways in which Novartis Pharmaceuticals Canada Inc. collects, holds, uses and shares information about individuals who visit this website as well as general information on the collection, use and disclosure of Personal Information in the context of our online activities. In this Privacy Policy, “Novartis”, “we” or “us” refers to such Novartis Pharmaceuticals Canada Inc.

We invite you to carefully read this Privacy Policy, which sets out in which context we are processing your Personal Information and explains your rights and our obligations when doing so. The term “Personal Information” as used in this Privacy Policy refers to information that can be used to identify you as an individual, including for example your name, birth date, e-mail address, mailing address, or telephone number.

Please note that we may periodically change, modify, add, remove or otherwise update this privacy policy from time to time by posting a new privacy policy on this website.

What Personal Information do we process and for which purposes?

Most of our services do not require any form of registration, allowing you to visit our site without telling us who you are. However, some services may require you to provide us with Personal Information, which may include your direct identifiers, such as name, birth date, email address or telephone number. We may collect and use Personal Information 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 which are evident from the circumstances or about which we inform you when we collect Personal Information from you.

Personal Information used for website usage analytics:

We may collect and process information about your visit to this website, such as the pages you visit, the website you came from and some of the searches you perform. Such information is used by us to help improve the contents of the site and to compile aggregate statistics using our site for internal, market research purposes. In doing this, we may install “cookies” that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. 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. , however, if you do not accept, you may not be able to use all functionalities of your browser software. We may also use external service providers to help us collect and process the information described in this section.

Occasionally, we may use internet tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) and cookies at this site and may deploy these tags/cookies through a third-party advertising partner or a web analytical service partner which may be located and store the respective information (including your IP-address) in a foreign country. These tags/cookies are placed on both online advertisements that bring users to this site and on different pages of this site. We use this technology to measure the visitors’ responses to our sites and the effectiveness of our advertising campaigns (including how many times a page is opened and which information is consulted) as well as to evaluate your use of this website. The third-party partner or the web analytical service partner may be able to collect data about visitors to our and other sites because of these internet tags/cookies, may compose reports regarding the website’s activity for us and may provide further services which are related to the use of the website and the internet. They may provide such information to other parties if there is a legal requirement that they do so, or if they hire the other parties to process information on their behalf. If you would like more information about web tags and cookies associated with on-line advertising or to opt-out of third-party collection of this information, please visit the Network Advertising Initiative website http://www.networkadvertising.org

We use Google Analytics to rationalize our portfolio of websites by (i) optimizing traffic to and between corporate websites, and (ii) integrating and optimizing web pages where appropriate. “Google Analytics” is a service offered by Google Inc. (“Google”) that generates detailed statistics about a website’s traffic and traffic sources and measures conversions and sales. Google Analytics uses “cookies” stored on your computer to help analyze how users use our website. The information generated by the cookies about your use of our website, including your IP address, will be anonymized by use of the appropriate settings prior to be transmitted to Google servers in the United States. For more information on how IP anonymization works, please see https://support.google.com/analytics/answer/2763052.

You may prevent or stop the installation and storage of cookies by you browser settings by downloading and installing the free Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout?hl=en. If you do not accept cookies, you may not be able to fully experience all functions of our website.

Google may transfer this information to third parties if required to do so by law or if a third party processes the information on Google’s behalf.

By using our website, you consent to the processing of any Personal Information that Google collects about you in the manner and for the purposes described above

Who has access to your Personal Information and to whom are they transferred?

We will not sell, share, or otherwise distribute your Personal Information to third parties except as provided in this Privacy Policy. We may share your Personal Information with other Novartis affiliates worldwide. Personal Information may also be transferred to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed, such as services delivery, evaluating the usefulness of this website, marketing, data management, or technical support.

These third parties have contracted with us to only use Personal Information for the agreed upon purpose, and not to sell your Personal Information to third parties, and not to disclose it to third parties except as may be permitted by us, as required by law, or as stated in this Privacy Policy.

Personal Information collected from you may also be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat Personal Information in accordance with this Privacy Policy.

Also, Personal Information may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding here or abroad.

The Personal Information we collect from you may also be processed, accessed, or stored in countries outside Canada. Such countries may offer a different level of protection of Personal Information. If we transfer your Personal Information to external companies in other jurisdictions, we will make sure to protect your Personal Information by applying the level of protection required under applicable data privacy laws.

For intra-group transfers of Personal Information, Novartis has adopted Binding Corporate Rules, a system of principles, rules, and tools, provided by European law, that ensures effective levels of data protection relating to transfers of Personal Information outside the EEA and Switzerland. Read more about the Novartis Binding Corporate Rules.

How do we protect your Personal Information?

To ensure the security and confidentiality of Personal Information that we collect online, we use data networks protected, inter alia, by industry standard firewall and password protection. In the course of handling your Personal Information, we take measures reasonably designed to protect that information from loss, misuse, unauthorized access, disclosure, alteration or destruction and against other unlawful forms of processing.

How long do we store Personal Information?

We will only retain your Personal Information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements.

What are your rights and how can you exercise them?

Whenever we process Personal Information, we take reasonable steps to ensure that your Personal Information is kept accurate and up-to date for the purposes for which it was collected. We will provide you with the ability to exercise the following rights under the conditions and within the limits set forth in the law:

If you wish to contact us regarding the use of your Personal Information, please email us at privacy.pharmacanada@novartis.com or reach out to us at the contact information stated in the Contact us section below. If you have provided consent, you may wish to withdraw consent. You may request to access your Personal Information as processed by us, or ask for correction, where applicable.

By contacting us, please note the name of the website related to your request, your relationship and/or interactions with us (as applicable), as well as the specifics of the information you would like us to provide.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services.

Any request to delete Personal Information will be subject to the ethical and legal obligations to which we are bound with respect to document reporting, storage and retention. We may take reasonable steps to verify your identity before giving you access to your Personal Information or making corrections thereto.

Terms of Use

Updated February 22, 2016

1. Acceptance

Your access to and use of this site (the “Site”) is subject to the following terms and conditions (the “Terms of Use”) and all applicable laws. By accessing and browsing this Site, you accept, without limitation or qualification, these Terms of Use.

2. Medical information/conditions

Product information on this Site is provided by Novartis Pharmaceuticals Canada Inc. and is intended for general information purposes only. This Site is intended for use in Canada only. Many pharmaceutical and medical device products listed are available upon prescription from a physician or qualified health care professional only, and not all such products may be available in all countries. The product information is not intended to provide complete medical information. SHOULD YOU HAVE A MEDICAL CONDITION, PROMPTLY SEE YOUR OWN MEDICAL DOCTOR OR HEALTH CARE PROVIDER. WE DO NOT OFFER PERSONALIZED MEDICAL DIAGNOSIS OR PATIENT-SPECIFIC TREATMENT ADVICE. You should always obtain complete medical information about your prescription medicines or medical devices (including their beneficial medical uses and possible adverse effects) by discussing the appropriate use of any medicine(s) or medical devices directly with your prescribing physician or, where appropriate, other medical advisor. Medical professionals may obtain complete medical information from the product’s information leaflet. Information on these products may vary by country. Patients, physicians and other medical professionals should check with local medical resources and regulatory authorities for information appropriate to their country. In addition, current regulations in many countries limit (or even prohibit in some instances) the ability of Novartis Pharmaceuticals Canada Inc. to provide information and/or to respond directly to patient questions regarding its prescription products. Novartis Pharmaceuticals Canada Inc., however, will respond to inquiries from and provide information to your qualified health care professional in accordance with applicable law and regulations.

3. Use of information

You may freely browse the Site, but you may only access, download or use information from this Site, including any text, images, audio, and video (the “Information“) for your own non-commercial use. You may not distribute, modify, transmit, reuse, repost, or use the Information for commercial purposes, without written permission of Novartis Pharmaceuticals Canada Inc. You must retain and reproduce each and every copyright notice or other proprietary rights notice contained in any Information you download. You should assume that everything you see or read on this Site is protected by copyright unless otherwise noted and may not be used except as provided in these Terms of Use or in the text on the Site without the written permission of Novartis Pharmaceuticals Canada Inc. Except as otherwise permitted in this paragraph, Novartis Pharmaceuticals Canada Inc. neither warrants nor represents that your use of materials displayed on the Site will not infringe rights of third parties not owned by or affiliated with Novartis Pharmaceuticals Canada Inc.. With the exception of the foregoing limited authorization, no license to or right in the Information, or any copyright of Novartis Pharmaceuticals Canada Inc. or of any other party is granted or conferred to you.

4. Trademarks/proprietary rights

You should assume that all product names appearing on this Site, whether or not appearing in large print, italics or with the trademark symbol are trademarks of Novartis Pharmaceuticals Canada Inc., its affiliates or licensors. This Site may also contain or reference patents, proprietary information, technologies, products, processes or other proprietary rights of Novartis Pharmaceuticals Canada Inc. and/or other parties. No license to or right in any such trademarks, patents, trade secrets, technologies, products, processes and other proprietary rights of Novartis Pharmaceuticals Canada Inc. and/or other parties is granted to or conferred upon you. All product names published in italics on this Site are trademarks owned by or licensed to the Novartis Group.

5. Disclaimer of warranties

While Novartis Pharmaceuticals Canada Inc. uses reasonable efforts to ensure that the Information is accurate and up to date, the Information may contain inaccuracies or typographical errors. Novartis Pharmaceuticals Canada Inc. reserves the right to make changes, corrections and/or improvements to the Information, and to the products and programs described in such Information, at any time without notice. Novartis Pharmaceuticals Canada Inc. makes no warranties or representations as to the accuracy of any of the Information. Novartis Pharmaceuticals Canada Inc. assumes no liability or responsibility for any errors or omissions in the content of the Site. ALL INFORMATION IS PROVIDED “AS IS.” NOVARTIS PHARMACEUTICALS CANADA INC. PROVIDES NO WARRANTIES ABOUT THE COMPLETENESS OR ACCURACY OF THE INFORMATION ON THIS SITE OR ITS POSSIBLE USES. CONSEQUENTLY, THE INFORMATION SHOULD BE CAREFULLY EVALUATED BY SITE VISITORS. NEITHER NOVARTIS PHARMACEUTICALS CANADA INC., NOR ANY OTHER NOVARTIS GROUP COMPANY, NOR ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING THIS SITE TO YOU SHALL BE LIABLE FOR ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, INDIRECT OR PUNITIVE DAMAGES ARISING OUT OF ACCESS TO, USE OF OR INABILITY TO USE THIS SITE, OR ANY ERRORS OR OMISSIONS IN THE CONTENT OF THE SITE. Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you. Novartis Pharmaceuticals Canada Inc. also assumes no responsibility, and shall not be liable for, any damages to, or viruses that may infect, your computer equipment or other property on account of your access to, or use of the Information. Novartis Pharmaceuticals Canada Inc. reserves the right to discontinue this Site at any time without notice and without liability.

6. Information you supply to us

Except for information covered by our Privacy Policy, any communication or material you transmit to the Site by electronic mail or otherwise, including any data, questions, comments, suggestions or the like is, and will be treated as, non-confidential and nonproprietary. Anything you transmit or post becomes the property of Novartis Pharmaceuticals Canada Inc. or its affiliates and may be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. Furthermore, Novartis Pharmaceuticals Canada Inc. is free to use, without compensation to you, any ideas, concepts, know-how, or techniques contained in any communication you send to the Site for any purpose whatsoever including, but not limited to, developing, manufacturing and marketing products using such information.

7. Worldwide products

This Site may contain information on worldwide products and services, not all of which are available in every location. A reference to a product or service on this Site does not imply that such product or service is or will be available in your location. The products referred to on this Site may be subject to different regulatory requirements depending on the country of use. Consequently, visitors may be notified that certain sections of this Site are intended only for certain kinds of expert users or only for audiences in certain countries. You should not construe anything on this Site as a promotion or advertisement for any product or for the use of any product that is not authorized by the laws and regulations of your country of residence.

8. Disclaimer

Nothing on this Site shall be interpreted as canvassing or public offering, nor constitute an invitation or offer to invest, subscribe, purchase or deal in the shares or any other securities of Novartis Pharmaceuticals Canada Inc. or any of its affiliates. In particular, actual results and developments may be materially different from any forecast, opinion or expectation expressed on this Site and the past performance of the price of securities must not be relied on as a guide to their future performance.

9. Links to this Site

Novartis Pharmaceuticals Canada Inc. has not reviewed any or all of the third-party websites which contain links to this Site and is not responsible for the content of any such off-site pages or any other sites linked to the Site. If you wish to link your website to this Site, you may only link to the home page. You may not link to any other pages within this Site without the prior written consent of Novartis Pharmaceuticals Canada Inc. Quotation or use of one or more portions of this Site in the site of any third parties without written consent is likewise prohibited.

10. Links to other sites

Links to third-party sites may be provided for the interest or convenience of visitors to this Site. We will endeavor to inform you when you are leaving this Site that the terms of use and privacy policy of the third-party site may be different. However, Novartis Pharmaceuticals Canada Inc. accepts no liability for links from us to others, and in particular we are not responsible for the accuracy or legality of the content thereof. We accept no liability deriving from a breach or omission in the privacy policies of third parties.

11. Postings to this Site

Although Novartis Pharmaceuticals Canada Inc. may from time to time monitor or review discussions, chats, postings, transmissions, message boards, and the like on the Site, Novartis Pharmaceuticals Canada Inc. is under no obligation to do so and assumes no responsibility or liability arising from the content of any such locations nor for any error, defamation, libel, slander, omission, falsehood, promotional materials, obscenity, pornography, profanity, danger, privacy disclosure or inaccuracy contained in any information within such locations on the Site. You are prohibited from posting or transmitting any unlawful, promotional, threatening, libelous, defamatory, obscene, scandalous, inflammatory, pornographic, or profane material or any material that could constitute or encourage conduct that would be considered a criminal offense, give rise to civil liability, or otherwise violate any law. Novartis Pharmaceuticals Canada Inc. will fully cooperate with any law enforcement authorities or court order requesting or directing Novartis Pharmaceuticals Canada Inc. to disclose the identity of anyone posting any such information or materials.

12. Consequences

If we become aware that you have violated any of the terms and conditions contained in these Terms of Use, we may immediately take corrective action, including preventing the user from using the services offered by Novartis Pharmaceuticals Canada Inc. and removing any information, data and content put on the Site by the user, at any moment and without notice. If we have been injured by your violation we may, in our sole discretion, seek to recover damages from you.

13. Revisions

Novartis Pharmaceuticals Canada Inc. may at any time revise these Terms of Use by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Terms of Use to which you are bound.