Schering-Plough Canada Inc. Privacy Policy

This Privacy Policy sets out how Schering-Plough Canada Inc. (hereinafter referred to as “Schering”, “we”, “our” or “us” in this Privacy Policy) collects, holds, uses and discloses Personal Information (defined below) about our customers (hereinafter referred to as “you”, “your” or “customer”), primarily in the context of consumer health products.

Our Commitment to Privacy

Schering is committed to providing our customers with superior service.  As providing this service involves the collection, use and disclosure of some Personal Information about our customers, protecting their Personal Information is important to us.

The purpose of this Privacy Policy is to inform you of our commitment to the protection of our customers’ Personal Information and the rules we intend to follow when we collect, hold, use or disclose Personal Information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ Personal Information and allowing our customers to request access to, and correction of, their Personal Information as required by applicable law.  We make every effort to handle our customers’ Personal Information in a manner that is consistent with applicable privacy laws.

We have designated a member of senior management as Schering’s Privacy Officer as detailed at the end of this Privacy Policy.  You may contact the Schering Privacy Officer for further information, to request access to or rectify your Personal Information held by Schering or to make complaints.  The Schering Privacy Officer regularly reviews our practices and procedures to ensure compliance with this Privacy Policy.

This Privacy Policy may be amended from time to time.

This Privacy Policy is comprised of  the following sections:

 

  1. The Information We Collect

    “Personal Information” is information about an identifiable individual.  Some business contact information, such as your business address or phone number, may not constitute Personal Information.  We may collect and maintain the following Personal Information in our customer files including:

    • Your name
    • Your mailing address and telephone number
    • Your email address
    • Any other information provided by you

    We collect Personal Information that is reasonably necessary to fulfill the following purposes:

    • To conduct surveys, in which you voluntarily participate
    • To administer our promotions or promotional contests in which you voluntarily participate
    • To send product information and special offers from Schering and its affiliated companies
    • To respond to your inquiries
    • To manage our business
    • To better understand your needs and how we can improve our products and services
    • To ensure compliance with the applicable laws and regulations
    • To ensure the security and processing of Personal Information

    In some cases, we may collect information on-line about you that is non-personally identifiable. Examples of this type of information include the type of Internet Browser you are using, the type of computer operating system you are using and the domain name of the Website from which you linked to our Website, advertisement or promotion.

  2. Consent

    If you provide Personal Information to Schering, you consent to the collection, use and disclosure of your Personal Information as described at the time of collection and as outlined in this Privacy Policy.  If you do not consent, please do not provide your Personal Information or, where applicable, exercise the opt-out options offered.  Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your Personal Information or you may withdraw your consent by contacting our Privacy Officer as detailed below.  We will explain the consequences of the withdrawal of your consent.  Your decision to withhold or withdraw your consent to certain uses of Personal Information may restrict our ability to provide certain services to you. 

    We may collect, use or disclose Personal Information without your knowledge or consent in limited circumstances, including:

    • When the collection, use or disclosure of Personal Information is permitted or required by law
    • When the Personal Information is available from a public source (e.g., a telephone directory)
    • To protect ourselves from fraud
    • To investigate an anticipated breach of an agreement or contravention of law
    • To comply with a subpoena or court order
    • To comply with the rules of court regarding the production of records

  3. Using and Disclosing Personal Information

    We will only use customer Personal Information where necessary to fulfill the purposes identified at the time of collection. We may disclose customer Personal Information:

    • To the customer, upon satisfactory proof of identity
    • To external auditors, at the request of regulatory authorities
    • To legal counsel

    We may also use and disclose your Personal Information to parties connected with the contemplated or actual sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. We will require that such parties treat your Personal Information in accordance with this Privacy Policy and to use and disclose it only for the purposes for which it was collected, including to provide the services or information that Schering would otherwise provide to you and generally to carry on Schering’s business.

    We do not sell or rent customer lists or Personal Information to unrelated third parties.

  4. Retaining Personal Information

    If we use customer Personal Information to make a decision that directly affects the customer we will retain that Personal Information for at least one year so that the customer has a reasonable opportunity to request access to it.  Otherwise, we will retain customer Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

  5. Accuracy of Personal Information

    We will use commercially reasonable efforts to ensure that customer Personal Information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.

    If you wish to request correction of your Personal Information in Schering’s custody or control, please make your request in writing to the Schering Privacy Officer and provide sufficient detail to identify the Personal Information and the correction or information being sought.

    We may need to verify your identity before correcting your Personal Information. 

    If your Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we may have disclosed the Personal Information.  We will note the customers’ correction request in the file, regardless of whether a change was made.

  6. Securing Personal Information

    We are committed to ensuring the security of customer Personal Information in order to protect it from unauthorized access, collection, use and/or disclosure.  We have physical, organizational, and technological security measures in place for Personal Information, whether in paper, mechanical, electronic or other form.

    We regularly review and update our security policies and controls to ensure ongoing Personal Information security as technology changes.

    The file containing Personal Information will be stored at Schering-Plough Canada Inc., 16711, TransCanada Highway, Kirkland, Quebec, H9H 3L1.  Only authorized Schering employees and our agents who are actively engaged in our promotions, surveys, services or product sales and development may access and use the Personal Information for the identified purposes.

    Each authorized employee or agent must acknowledge their understanding of this Privacy Policy and our privacy procedures.  The Privacy Policy terms have been explained and understood by each authorized employee or agent.

    Schering also requires its service providers to provide comparable security measures with respect to any Personal Information being processed by them on behalf of Schering.

  7. Providing Customers Access to their Personal Information

    Customers have a right to access their Personal Information, subject to limited exceptions.  A request to access Personal Information must be made in writing to the Privacy Officer and provide sufficient detail to identify the Personal Information being sought.

    In some circumstances, we may not be able to provide access to your Personal Information, for example if it contains the Personal Information of other persons, if it constitutes confidential commercial information, or if it is protected by solicitor-client privilege.  If we deny your request for access to, or refuse a request to correct, your Personal Information, we will advise you of the reasons for this refusal.

    Upon request, we will also tell customers how we have used their Personal Information and to whom it has been disclosed. 
    A minimal fee may be charged for providing access to Personal Information.  Where a fee may apply, we will inform the customer of the cost in writing prior to proceeding with the request.

    If a request for access is refused in full or in part, we will notify the customer in writing, providing the reasons for refusal and the recourse available to the customer.

  8. Changes to this Privacy Policy

    Schering reserves the right to change this Privacy Policy at any time and we will take reasonable steps to advise you of any material changes.  However, you should review this Privacy Policy from time to time to ensure that you are aware of and accept any changes made.  Your continued consent to our collection, use and disclosure practices following notification of any material change and/or your continued access of our Website following the posting on the Website of any material changes to the privacy policy will signify your acceptance of, and agreement to be bound by, the terms of the modified Privacy Policy.

  9. Contact Schering’s Privacy Officer

    If you have concerns or questions regarding Schering’s compliance with this Privacy Policy, or require further clarification on any of our privacy policies, you can contact Schering’s Privacy Officer in writing at:  Schering-Plough Canada Inc., 16711, TransCanada Highway, Kirkland, Quebec, H9H 3L1 or by phone at 514-428-3675 or 1-800-361-7031.

  10. Our Commitment to Children’s Privacy

    Protecting the privacy of the very young is especially important.  For that reason, we are not in the practice of knowingly collecting or maintaining information at the Website from children under 13, and the Website is not intended to attract anyone under 13.

    Where appropriate, we will specifically instruct children NOT to provide such information to us.  If a child has provided us with personally identifiable information, we ask that a parent or guardian of the child contact us at 1-800-361-7031 to request that this information be deleted from our records.  We will use reasonable efforts to delete the child’s information from our existing files.  This Privacy Policy applies to Canada and is governed by the laws of the Province of Quebec and the laws of Canada applicable therein.