Last Updated: July 20, 2019
We Value Your Privacy
JAMP Pharma Corporation (“JAMP”) recognizes that your privacy is very important to you and is committed to maintaining the accuracy, confidentiality, and security of your “Personal Information”.
“Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, contact information, mailing address, date of birth, medical information (such as your date of surgery), type of surgery, type and size of products, current and previous product usage information, health care provider information (including your applicable account information with such health care providers), and JAMP usernames and passwords, and any information provided by you about your use of our website and products.
Personal Information, however, does not include your name, business title or business address and business telephone number in your capacity as an employee of an organization. Personal Information will only be collected and retained for legitimate purposes. It will be necessary to collect and use Personal Information about our customers when they view our website “https://www.jamppharma.ca/ or http://www.jamppharma.com ” (the “Website”) or when providing our services.
Scope
Our Privacy Policy is designed to help you understand the types of information that we collect in connection with the Website and our services, how we use and share the information, and how the information is protected with procedures that meet or exceed all Federal and Provincial requirements. This Privacy Policy also details the purposes for which we use that data, and your choices regarding the use and distribution of your data.
JAMP shall not collect, use, or disclose any Personal Information about any party (an “Individual”) without that Individual’s knowledge and consent, except as herein provided or as may be specifically permitted or required by applicable law. By accessing our Website, you consent to the terms and conditions of this Privacy Policy, including the data collection and use practices described herein.
We will not share your Personal Information with third parties except as otherwise stated in this Privacy Statement.
Collection and Use of Personal Information
The collection, use, and/or disclosure of Personal Information in the business context is essential to the conduct of many of JAMP’s business functions. JAMP collects and uses Personal Information in a lawful manner and only when it is reasonably necessary to do so for the provision of requested services, products, or information or as may be required or permitted by applicable laws. This information is generally provided voluntarily by an Individual in purchasing our products, applying for our services, viewing or sharing information on the Website. For example, JAMP may collect Personal Information for the purposes of requests for product information, clinical trials, registration for JAMP programs, education, employment, disease management, decision support systems, customer service support, marketing or JAMP surveys.
Whenever JAMP requests Personal Information, we will explain the purposes for which that Personal Information is required. The collected Personal Information will be used only for the stated purpose, a requisite ancillary purpose, or for such other purposes to which the customer may later consent. Individuals should not provide JAMP with any Personal Information that is not specifically requested.
Rights to Opt-In/Out
JAMP may disclose, subject to applicable laws and regulations, Personal Information without an individual’s consent (opt-in) to agents which assist JAMP with its business activities. Our agents include any third party that collects and/or uses Personal Information under the instructions of JAMP, or to which JAMP discloses Personal Information for use on JAMP’s behalf. Such agents may include service providers that administer JAMP’s e-mail subscriptions and requests for information or provide services in connection with employment applications. JAMP requires such agents to keep Personal Information confidential and to use and/or disclose Personal Information only to perform functions for JAMP and in accordance with JAMP’s instructions and this Privacy Statement.
In accordance with applicable law, and as appropriate, JAMP will offer individuals the opportunity to choose (optin/ out) whether their Personal Information is to be (a) disclosed to a non-agent third party, or (b) used for a purpose other than that for which it was originally collected, authorized and/or consented to by the individual. However, JAMP may be prevented from providing certain services to individuals who do not consent to the use, access, or disclosure of their Personal Information.
If an individual is asked to provide sensitive Personal Information, such as economic or financial information, JAMP will, in accordance with applicable law, give individuals the opportunity to affirmatively and explicitly authorize or consent (opt-in) to the disclosure of their sensitive Personal Information to a non-agent third party or the use of their sensitive Personal Information for a purpose other than the purpose for which it was originally collected and/ or authorized or consented to by the individual
Metadata and Cookies
Some Personal Information may be collected automatically upon your visit to our Website, in a form known as “Metadata”. This Metadata may include, without limitation, the following information about your visit to our Website: the materials you accessed and viewed, and links that you clicked. JAMP may also obtain certain standard Metadata such as your Internet Protocol (IP) address, your browser type, the date and time you access the Website, or if you access the Website through a mobile device, your device type and identifier.
Cookies from this Website may also collect non-personal information. Cookies are small amounts of data stored directly on the device you are using. Cookies allow us to collect Personal Data such as browser type, time spent on the Website, pages visited, and language preferences. JAMP and our service providers may use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Website. A cookie will not collect any information that is not otherwise provided to us. Cookies allow a website to identify repeat visitors through an ID number cached in that computer. Cookies can be disabled or cleared using the tools of any web browser.
How We Use Your Personal Information
Without limiting the generality of any of the foregoing, JAMP may use an Individual’s Personal Information as set out in this Privacy Policy.
When an Individual registers for the Website, JAMP collects and retains personal information such as the Individual’s name and contact information. JAMP will use this information to confirm the Individual’s registration status and to maintain the Individual’s account.
Personal Information, including credit card or other financial information, is collected when an Individual purchases a product or service. JAMP will use this information as reasonably necessary to process the transaction.
JAMP may seek an Individual’s consent to use his/her contact information to provide newsletters, bulletins, or other similar communications.
JAMP may also retain and use Personal Information voluntarily provided by an Individual to develop and improve its product services and offerings.
Disclosure of Personal Information
Access to Personal Information is limited to JAMP employees on a “need-to-know” basis or where their duties reasonably require such information, agents with whom JAMP contracts to carry out business activities for JAMP, and, to the extent applicable, certain companies with which JAMP may conduct joint programs. JAMP trains its employees about the importance of privacy and how to handle and manage Personal Information appropriately to protect its security.
We may need to disclose your Personal Information to our subsidiaries and affiliates, certain third-party agents, service providers, or professional advisors, in carrying out the requested services or as necessary for completing the otherwise permitted uses of Personal Information only to the extent that may be reasonably expected to deliver the services or improve the provision of the services. In such circumstances, JAMP shall ensure that any such parties having access to your Personal Information have appropriate safeguards in place to reasonably ensure the protection of your Personal Information and shall be prohibited from using your Personal Information for any other purpose. Personal Information handled by any such parties is governed by this Privacy Statement and applicable privacy or data protection legislation.
For example, JAMP will require contractual obligation that the third-party agents provide at least the same level of protection as is required by JAMP’s Privacy Policy. Where JAMP has direct knowledge that a third-party agent is using, accessing, or disclosing Personal Information in a manner contrary to this Privacy Statement, JAMP will take steps to prevent or stop the use, access, or disclosure, in accordance with applicable law.
In addition, JAMP may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. However, to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
JAMP may disclose Personal Information if required to do so by law enforcement officials, regulatory bodies, or government agencies to comply with any legal requirements or legal processes. JAMP may also disclose Personal Information to protect and defend our legal rights or against legal claims or in connection with an emergency that warrants use or disclosure of the information or to protect the personal safety of an individual, in other circumstances for public security or for other public interest purposes.
JAMP may also be required to, subject to applicable law, use and/or disclose Personal Information, in connection with a contemplated or actual reorganization of its business, when seeking financing or in connection with an assignment, sale, or other transaction involving the disposal of all or part of its business or assets, for example, to allow third parties to conduct due diligence so as to determine whether a transaction should proceed and on completion of the transaction. In any assignment or sale, the assignee or purchaser may use and/or disclose Personal Information collected by JAMP for substantially the same purposes and subject to the same safeguards, as described in this Privacy Statement.
No Third-Party Direct Marketing Use
JAMP shall not sell or otherwise disclose Personal Information to third parties for their own direct marketing use, commercial, or other reasons, except as may be specifically required to comply with applicable laws, or upon providing clear notice to you and obtaining your explicit consent for your Personal Information to be shared in this manner or for any purpose other than those for which it was explicitly or implicitly given.
Integrity of Personal Information
JAMP will use Personal Information only in ways that are compatible with the purposes for which it was collected and/or consented to by the individual. JAMP will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. JAMP will only store Personal Information for as long as it is needed to fulfill the purposes for which it was collected and as permitted or required by law.
Security of Information and Retention
At all times, JAMP employs reasonable physical organizational, technical and administrative measures to protect your Personal Information. Access is limited to authorized personnel who are appropriately trained to handle Personal Information. However, you acknowledge that the security of any data transmission over the Internet or data storage systems cannot be guaranteed.
JAMP will not retain any Personal Information, except as may be required by any Federal or Provincial record keeping requirements, longer than is necessary to fulfill the purpose(s) for which the Personal Information was provided. Once your Personal Information is no longer required to fulfill the stated purpose or to comply with applicable laws, it will be either destroyed or converted into a form that prevents an Individual from being identified
Compliance Review
JAMP will conduct periodic compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy.
Disclaimer of Warranties and Liability
You expressly understand and agree that JAMP shall not be liable for, and expressly release JAMP, its affiliates and their respective officers, directors, employees and agents from any liability whatsoever for, any direct, indirect, incidental, special, consequential, or exemplary damages, including without limitation, damages for loss of profits, goodwill, use, data loss, or other losses (even if JAMP has been advised of the possibility of such damages) resulting from or arising in connection with: (i) the collection, use or disclosure of your Personal Information; or (ii) any matter otherwise related to the Personal Information provided to us by you and/or via your use of the Website.
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through the Website or to which the Website contains a link.
Updates
This Privacy Policy may be updated from time to time. Commercially reasonable efforts will be made to notify you of any substantial changes to the terms of the Privacy Policy. For example, we shall revise the “last updated” date at the top of the webpage on which this Privacy Policy is posted.
Questions and Enquiries
Customers may direct any questions or enquiries with respect to this Privacy Policy or about our practices by contacting:
JAMP Pharma Corporation
Attention: Privacy Officer
1310 Rue Nobel,
Boucherville, QC J4B 5H3
Email: custjamp@jamppharma.com
Any complaints received regarding JAMP’s use or handling of Personal Information will be investigated within a reasonably timeframe. Upon concluding the investigation, the Privacy Officer will respond to the complaint and, if necessary, JAMP will take appropriate measure to rectify the situation and maintain compliance with applicable law.
Should you wish to access your Personal Information that is held be us, individuals are entitled, with certain legal restrictions, to do so. Such legal restrictions include, without limitation, if providing access to the Personal Information would impede a criminal investigation or result in the disclosure of other protected information. Upon receiving any such request for access, we shall respond within a reasonable timeframe and shall either provide access to the Personal Information and/or, if permissible, explain why access is denied if any Personal Information cannot be provided. Requests for access to Personal Information should be made to the Privacy Officer as set out above.
In addition, JAMP will, to the extent required by applicable law, permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, subject to certain exceptions.
Individuals may revoke (opt-out) at any time, to the extent permitted by applicable law, their consent and/or authorization to use and/or share their Personal Information. All requests to revoke or amend consent should be in writing to JAMP as directed above.
