1. Collection of Personal Information.
(a) Personal Information. Personal information is information about an identifiable individual, and includes name, title, postal address, telephone number, email address, age, occupation and other information set out in the applicable privacy laws.
In carrying out our business, we collect various types of personal information with consent of the individual or when required or permitted by law, and this includes information about patients, healthcare professionals (including physicians, pharmacists, and nurses), participants in clinical studies, customers, visitors to our Site, and individuals who contact our offices. The types of personal information that we may collect include the following:
- the names and other contact information of visitors to our Site who submit online requests for information on our products or responses to our questionnaires, surveys, feedback forms, or who participate in our online health assessment tools, chat rooms or other discussion forums
- names and other contact information on patients who use our products and services, when contacting us (whether directly or through our parent, subsidiaries, affiliates or third party service providers assisting us in our administration of a service or program) to seek additional information about our products or services, in which case we may also collect the patients’ personal health information and medical histories to enable us to provide information that we believe is relevant to the patients’ health condition
- information about a patient’s lifestyle or household as this can often determine a patient’s ability to manage his or her medical condition
- information about a patient’s or a clinical study participant’s health and adverse reaction to our product in our reports to Health Canada or other regulatory agencies
- names and other contact information of patients who wish to participate in our clinical studies or to access products that are not currently commercially available in Canada or other countries
- information that we may collect during meetings with healthcare professionals, including information regarding their areas of practice or specializations, professional qualifications and other credentials as well as any questions, comments and opinions that they may have about our products or services
(b) Cookies. During your visit to our Site, we may also collect information about how you are using our Site, to help us improve the design and layout of our Site so as to enhance your online experience. We do this through the use of “cookies” and other site-usage information technologies. “Cookies” are small text files containing a unique identification number that is automatically stored on the visitor’s computer. The information collected helps us determine traffic patterns and site usage, including the total number of visitors, whether a visitor is a new or repeat visitor, the types of internet browsers and operating systems used by the visitor, and information provided or received by the visitor in the last chat room or other discussion forums. No additional personal information is stored in these “cookies”. We do not link this information to any other personal information that you may voluntarily provide to us at our Site. If you do not wish to accept “cookies”, you may set your browser to block or refuse them. However, some functions on the Site may be impacted if “cookies” are not allowed.
(e) Sites Linking to Us. We do not endorse, and are not responsible for, websites that link to our Site.
2. Use of Personal Information. Personal information that we have collected may be used for one or more of the following purposes:
- to monitor interest in information contained on our Site for marketing and research purposes and to make improvements to our Site, its content and ease of use
- to administer questionnaires, surveys, chat rooms and other discussion forums
- to respond to questions, feedback, comments and other submissions
- to make improvements to our products and services
- to respond to inquiries regarding our clinical trials
- to follow up and otherwise gather more information on reports of adverse events or complaints relating to our products or services
- to advise Health Canada and/or other regulatory agencies of adverse drug reactions and other related events in compliance with applicable laws
- to provide clinical evaluation packages to healthcare providers and obtain their feedback
- to obtain the advice of healthcare professional experts on research and development programs and clinical trial design and results
- to establish and support educational programs to raise awareness of a health condition and health management practices as well as scientific and clinical developments
- to notify patients and healthcare professionals of product-related matters, including product recalls
- to market and promote our products and services
- to otherwise comply with regulatory, securities and other applicable laws
- to respond to court or administrative orders, or to bring or defend against legal actions
3. Disclosure of Personal Information. We may disclose or transfer your personal information under the following circumstances:
- to Canadian and/or other international regulatory authorities as required, if you are reporting an adverse event or side effect
- to your healthcare providers, at your request, whether to obtain certain medical information from your healthcare provider, to provide certain product information to your healthcare provider or to otherwise assist you in participating in our program offerings
- to a court, administrative tribunal, governmental authority or other body authorized to compel the disclosure of your personal information, for the purpose of complying with legal requirements such as a law, regulation, search warrant, subpoena, or court or administrative order, or as otherwise required or permitted by applicable law
- if the rights or property of Turnstone, its parent, subsidiaries, affiliates, third party service providers or the users of our Site may be compromised
- if the personal safety of users of our Site or other members of the public may be compromised
Please note that any of these disclosures may involve the storage or processing of personal information outside of Canada and may therefore be subject to different privacy laws than those applicable in Canada, including laws that require the disclosure of personal information to governmental authorities under circumstances that are different than those that apply in Canada.
4. Your Consent. We collect, use and disclose your personal information with your consent, except as required or permitted by law. Your consent to the collection, use and disclosure of personal information may be express (that is, where you were asked specifically for your consent, whether verbally or in writing) or implied (where your consent is necessary in order for us to provide the information, product or service requested), depending on the circumstances. Consent may also be provided in circumstances where notice has been given to you about how we would like to use your personal information and you have not withdrawn your consent, for example, by indicating that you would like to “opt out” of allowing us to use or disclose the personal information for the purpose we had specified.
Where an individual is not capable of consenting to the collection, use or disclosure of his or her own personal information but you wish to provide us with that information, please ensure that consent is obtained from the person who is legally entitled to consent on behalf of that individual if such person is not you.
Consent may be withdrawn at any time, subject to contractual and legal restrictions and provision of reasonable notice. Please be aware that if you withdraw your consent to certain uses of your personal information, it may no longer be possible for us to provide you with certain information, products or services. Also, under some circumstances, you will not be permitted to withdraw consent to certain necessary uses and disclosures of personal information that you have originally consented to. For example, we may be required or permitted by law to collect, use or disclose (and store) personal information without your consent, to comply with other laws, an order of the court or other legal administrative tribunal or body, or an authorized inquiry of a government agency or to collect a debt owed to us or enforce a right under a contract.
6. LEGAL DISCLAIMERS.
(a) Informational Purposes Only. The content of our Site is for informational purposes only. It is not intended to be a substitute for professional medical advice, diagnosis or treatment. Always seek the advice of your physician or other qualified healthcare provider with any questions you may have regarding a medical condition. Never disregard professional medical advice or delay in seeking it because of something you have read on our Site. None of Turnstone, its parent, subsidiaries, affiliates, or other contributors to this Site can be held responsible, whether directly or indirectly, for any harm, injury, damage, loss or inconvenience which might arise from the use of this Site or from your reliance on any information provided on this Site.
(b) No Guarantee of Technical Security over the Internet. Although we employ technical security measures to protect the confidentiality of your personal information, no transmission over the Internet can be guaranteed to be completely secured. Therefore, Turnstone, its parent, subsidiaries, affiliates, third party service providers and their respective directors, officers, employees and agents do not represent, warrant or guarantee that personal information will be protected against misuse, loss, alteration or release, and do not accept any liability for personal information submitted to them or for your or any third party’s use, misuse or disclosure of personal information. Further, it is your responsibility to safeguard the confidentiality of your usernames and passwords that allow you access to secured areas of our Site.
(c) Use of Communications. We intend to use the general content of communications, including ideas, inventions, concepts, techniques or know-how for other purposes including developing, manufacturing and/or marketing goods or services.
(e) Governing Laws of Ontario. Your access to and use of our Site and the contents hereof shall be governed by and interpreted in accordance with the laws of the Province of Ontario and the laws of Canada applicable therein without any conflict of law rules or principles that may make the laws of another jurisdiction apply.
7. OUR PRIVACY OFFICER.
Turnstone Biologics Inc.
787 Bank Street, 2nd Floor
Canada K1S 3V5
Tel: 613-421-8930 ext. 232
787 Bank Street, 2nd Floor
Ottawa, Ontario K1S 3V5
New York City
110 East 25th Street
New York, New York 10010