Privacy Policy

SECTION 1. – MANTRASSISTANCE

www.mantrassistance.ca

MANTRASSISTANCE is a patient support program (the “Program”) offered by MANTRA PHARMA INC. and/or its affiliates (collectively, “Mantra”) for patients prescribed any one of Mantra products eligible for such Program.

As part of its business, Mantra outsources the administration of its Programs to third parties service provider and their respective employees (collectively, the “Program Administrator”).

In keeping with its mission and values, Mantra makes it a priority to respect your privacy.

By transacting with the Program Administrator via its website or by registering to the Program, you hereby accept and undertake personally (or on behalf of any entity for which you are mandated, as the case may be) to respect the Privacy Policies set out by the Program Administrator as well as all applicable laws and regulations (collectively, the “Policies”).

If you have any questions regarding the application of the Program, its Policies or the management of your personal information, do not hesitate to contact the Program Administrator using the contact information provided on its website.

By enrolling in the Program or accessing the Program Administrator’s website, you acknowledge that the Program Administrator shall be the sole and exclusive owner of all data and information (including personal information) collected or created through the Program with respect to your registration and participation in the Program, as well in view of all activities performed by pharmacists or personnel of pharmacies that are registered or participating in the Program. Except for legal requirements and notably in case of an adverse event or a complaint about a Mantra product, Mantra will not have access to any of your personal information. Any statistical data related to the Program, if any, will be rendered in an aggregated and anonymous manner and shared with Mantra.

The website https://www.mantrassistance.ca is the exclusive property of Mantra and is designed to provide added value service to all patients.

 

SECTION 2. – GROUPE MANTRA

www.groupemantra.ca/en/

In general, with the exception of MANTRASISTANCE website (provided in Section 1 herein), by accessing Mantra’s website (including Mantra Pharma Inc., Mantra Solutions Inc., Mantra Distribution Inc., Myriad Pharma Inc., as well as all their subsidiaries, if any), Mantra may solicit, collect, use and disclose some of your Personal Information for serious and legitimate reasons.

For the purposes of this Privacy Policy, “Personal Information” means any information that allows Mantra to identify you personally, including, but not limited to, your name, address, telephone number, email address, date of birth, medical information, information about your current or past use of Mantra products and services, credit card information and order history, your Mantra user ID and password, and any information collected through your use of Mantra’s website and its products and services. Note that information relating to your professional capacity, such as your name, title and business address, is not subject to this Privacy Policy.

In the course of its business, Mantra may solicit, collect, use and disclose some of your Personal Information for serious and legitimate reasons.

For purposes of clarity and transparency, below you will find provisions relating to your consent, the type of Personal Information collected and the means by which it may be retained, used and/or disclosed, the safeguards for its protection, and your rights with respect to the use of your Personal Information.

1. Consent

By law, Mantra’s use of your Personal Information is permitted only with your consent, subject to certain exceptions.

Therefore, where possible, Mantra will ask for your consent before collecting or using your Personal Information by notifying you of the information to be collected and the manner in which it will be used. However, in some cases, it may not be necessary or possible to obtain your consent before collecting or using your Personal Information.

By transacting with Mantra, whether by accessing its website or communicating directly with Mantra (by telephone, email or in person), you agree to make your Personal Information subject to the terms and conditions set out in this Privacy Policy, including the Terms of Use of Mantra’s website.

Note that where “Sensitive Personal Information” is involved, that is, information that entails a high level of reasonable expectation of privacy, Mantra undertakes to obtain your express consent.

In addition, should Mantra wish to collect, use or disclose some of your Personal Information for commercial or philanthropic prospection purposes, Mantra undertakes to expressly disclose such information to you, and you may then withdraw your consent.

Lastly, be advised that, subject to legal obligations to which Mantra is subject, you may withdraw your consent to the use of your Personal Information at any time. To do so, you must provide reasonable advance notice to Mantra’s Privacy Officer, in accordance with the provisions set out in section VII below. We will then inform you of the consequences of such withdrawal.

2. Collection, use and disclosure of Personal Information

a. Collection

As mentioned above, Mantra may collect Personal Information about its customers, employees, consumers, agents, partners, patients and/or participants in clinical studies or trials, among others. Mantra undertakes to collect such Personal Information by lawful means and only to the extent that such information is necessary to (i) conduct its business, (ii) provide you with products or services or (iii) otherwise communicate with you.

Thus, Mantra may obtain Personal Information about you either directly (for example, as part of an online order or the provision of a service, a request for information on the Mantra website, participation in a clinical trial or study, receipt of applications for recruitment purposes, processing information obtained as part of pharmacovigilance operations or as a result of a call to one of Mantra’s offices) or indirectly (such as information obtained from healthcare professionals through a computer or telephone).

For clarification purposes, be advised that Mantra does not knowingly collect information about minors. Should this happen, Mantra undertakes to abide by all the legal and regulatory provisions applicable to such a case.

b. Use

As part of its operations, Mantra processes the Personal Information it collects for several purposes, for example, in order to:

  • Process online orders and complete transactions
  • Perform pharmacovigilance operations
  • Answer requests and questions regarding Mantra products and services and assist Mantra customers
  • Enhance and improve customer experience on the Mantra website
  • Maintain, secure and analyze its IT systems, databases or software
  • Collect information about, develop and improve its products and services
  • Conduct research and development
  • Collect information on clinical trials
  • Conduct recruitment
  • Reorganize or modify the Mantra organization
  • Collect accounts receivable
  • Send information about Mantra products and services
  • Conduct marketing and business development activities
  • Disseminate promotional materials, newsletters, offers or other information about Mantra
  • Meet its legal, regulatory or risk management obligations
  • Process complaints
  • Process data contained on its IT systems

c. Disclosure

Personal Information collected may be disclosed to and processed by any entity in the Mantra network.

Your Personal Information may also be shared with third persons. In such cases, only Mantra representatives, agents, advisors, mandataries, subordinates and/or employees having a legitimate reason to take cognizance of your Personal Information will have access to it. These persons include service providers assisting Mantra with its website and IT systems and other marketing and pharmacovigilance consultants.

In such cases, Mantra will ensure that they keep all your Personal Information confidential and use it only as part of the performance of their services for Mantra and in accordance with this Privacy Policy. In the interest of integrity, Mantra will require such third persons to provide the same level of protection as that required by this Privacy Policy.

Subject to the foregoing, Mantra undertakes to not disclose your Personal Information to any third person or use it for any unrelated purpose and further undertakes to not disclose any nominative list containing your Personal Information without your consent, unless otherwise required by law.

Mantra may, however, disclose your Personal Information if a government agency charged with enforcing the law, including the Commission d’accès à l’information or any other government agency or body, requests that it do so, or in connection with any judicial proceedings. Subject to applicable law, Mantra may also disclose Personal Information where such disclosure is necessary to complete a commercial transaction to which Mantra intends to be a party.

d. Retention

Mantra takes reasonable steps to ensure that the Personal Information collected, processed and retained is complete, up-to-date and used only for the purposes for which it was collected or for which authorization was given.

Mantra retains Personal Information only for the time required for the specific purpose for which it was collected or as required by law. For more information on how long we retain Personal information, please contact us using the contact information in section VII below.

As required by law, Mantra will destroy, anonymize or convert the Personal Information collected to a format that makes it impossible to identify you when the purposes for which it was collected are fulfilled or to comply with the law.

3. Data security

Mantra undertakes to protect your Personal Information and take appropriate security measures to ensure that Personal Information is collected, used, disclosed, retained or destroyed in accordance with the law, by implementing administrative, physical and technological security controls.

However, Mantra cannot guarantee that third parties will not attempt to breach the security measures in place or use your Personal Information for improper purposes. Mantra will not monitor the websites to which it may link, including those of its partners and sponsorships. Thus, Mantra’s Privacy Policy does not apply to third-party websites.

Any third-party website that you may access by clicking on a link will have its own personal information protection policies. Mantra cannot be held liable for any harm resulting from the practices of third parties.

In addition, if Mantra has reason to believe that a confidentiality incident, as defined by law, involves any of your Personal Information, Mantra will take reasonable steps to prevent prejudice and similar incidents from recurring. It will also ensure that the competent authorities are informed in a timely manner.

However, it is well known that no method of transmission over the Internet or means of electronic storage is completely secure. Consequently, Mantra cannot give you assurance or warrant that your Personal Information will remain secure. It is possible that your Personal Information may be accessed, disclosed, altered or destroyed as a result of a breach of Mantra’s safeguards. If you have reason to believe that your Personal Information has been compromised, please contact us immediately.

4. Request for access, rectification, deletion and/or de-indexation

At any time, and subject to certain legal restrictions, you may make a request to (i) access your Personal Information collected by Mantra, (ii) rectify your Personal Information, (iii) cease the dissemination of your Personal Information, or (iv) de-index any hyperlinks to such Personal Information, by submitting a written request to that effect.

Mantra will process all requests in a diligent and timely manner. If you are a person with a disability, reasonable accommodation may be made, upon request, to enable you to exercise your right of access under this Privacy Policy.

If, for any reason, Mantra refuses to grant your request, it will notify you in writing, providing reasons for its refusal and informing you of your recourses.

Should the information collected be health-related, Mantra reserves the right to temporarily refuse that your file be consulted if it deems, further to the advice of a health professional, that your consultation of your file would result in serious prejudice to your health. Finally, note that Mantra may not be able to cease using your Personal Information if it becomes necessary to use it to fulfill obligations imposed by law.

5. Outside Quebec

If, as part of its operations, Mantra discloses your Personal Information outside Quebec, it will first ensure that the information will not be used for irrelevant purposes.

In the case of the use of nominative lists outside Quebec, you will have a valid opportunity to refuse that your Personal Information be used for commercial or philanthropic prospection purposes and have such information deleted from the list should you express your refusal.

To the extent that any of your Personal Information is used outside Canada, it may be subject to the laws of the country in which it is retained and used, and, in such cases, may be subject to various forms of disclosure to government authorities, courts or agencies charged with enforcing the law, in accordance with the laws of that country.

6. Business

Mantra hereby certifies that at no time does it engage in the business of compiling files on others, or preparing and communicating to third persons credit reports concerning the character, reputation or creditworthiness of persons that could be named in such files.

7. Contact Us

If you have any questions regarding the application of the foregoing, please contact Mantra’s Privacy Officer using the contact information below.

Senior Legal Counsel
1000, Du Lux, Office 201
Brossard, Quebec  J4Y 0E3
confidentialite@mantrapharma.ca
450-678-7088

Mantra makes every effort to keep this Privacy Policy up to date. It may therefore be amended from time to time without prior notice. Your use of Mantra’s website after such amendments have been made will be considered acceptance of these amended terms.