1. Privacy Statement
Welcome to www.drscholls.ca/en (the “website”), administered by Scholl’s Wellness Company. (“SWC”). This website is intended for Canadian residents only and is subject to all applicable Canadian laws.
This Privacy Statement outlines how personal information about you is collected, used, disclosed and otherwise processed by SWC with respect to your use and interaction with SWC via this website as well as through other online activities involving SWC products and services (“Services”). This Privacy Statement also applies to the personal data we collect offline, such as when you call us or interact with SWC in person, such as at an industry event or at a place of business.
2. Personal Data
Personal data is information about an identifiable individual. Personal data does not generally include business names and business contact information used in a commercial context.
3. Consent to Collection of Data
In cases when personal data is provided to others to provide you products or services you have requested, or for other purposes you have authorized, we rely on technical and organizational means to assure that applicable data security regulations are followed.
4. How Does SWC Collect Personal Data?
Generally, we only collect personal data when you provide it to us, through registration, completion of forms or e-mails, as part of an order for products or services, inquiries or requests about materials being ordered and similar situations in which you have chosen to provide the information to us. If you do not want your personal information collected, do not provide it to us.
5. What Type of Personal Data Does SWC Collect?
Examples of personal data we collect and use are:
- Contact information, such as full name, email address, telephone number and mailing address
- Usernames and passwords
- Business and professional information, such as title, practice, specialty, education, certification, accreditation, association
- Expertise and special interests, such as degrees, therapeutic specialty, specific disease expertise, practice setting, years of practice, department
- Banking and other information as required to pay honorariums and make travel arrangements
- Demographic information including age, gender, images and videos
- Consumer and professional preferences and comments, including with respect to SWC Services
- Clinical trial data, including demographic, medical and health information of patients
- Data that must be reported to Health Canada and other regulatory bodies
- Sensitive health and patient data provided to SWC through adverse event reports, recalls or other notifications
- Information submitted through SWC chat boards, health centres, consumer and professional contact forms and call lines
- Information you provide when you contact us, provide feedback, make a complaint or other inquiry
6. How Do We Use the Data?
The data we collect will be used for the purpose of supplying you with the requested Services or for other purposes for which you have given your consent, except where otherwise provided by law. For health care professionals, researchers, scientists and other professionals, the information we collect is primarily to continue and improve our client relationship with you. The information collected assists in maintaining our client relationship management databases. Other purposes may include:
- Creating and managing your user account
- Providing our programs, clinical trials, research programs and events
- Providing you with approved medical or scientific information
- Administering travel arrangements to industry events provided by SWC and our partners
- Meet our obligations required by applicable laws, i.e. reporting to Health Canada, enforcing our terms
- Analyze the accuracy and effectiveness or our website and Services, including administer, troubleshoot and enhance the website and Services
- Analyze data, identify trends and issues and create statistical reports
- Administer contests, promotions and surveys
- Test and analyze our Services for efficacy, safety and enhancements
- Establish and maintain our business relationship with you
- Responding to inquiries, complaints and other communications
The data we collect will also be used to improve the content of our website, and may be used to contact you via e-mail or by regular mail, to provide you with information that we believe to be of interest to you, process and store the information provided so that we are able to better understand your needs and how we can improve our products and services and to provide you with health-related information or services that we believe would be of interest to you. See “Your Options” to learn what choices you have.
7. Does SWC Share or Disclose Personal Data?
SWC may share and disclose personal and technical data in the following circumstances:
Service Providers: Like many businesses, SWC uses third party service provides to assist in administering and providing the website and our Services. Providers assist SWC in data storage, website hosting, marketing, customer service, mailing, etc. Your personal data will not be passed by our service providers for use by third parties in any form whatsoever, unless we have obtained your consent or are legally required to do so.
Legal Requests and Obligations: SWC may disclose personal data when required by law, such as to respond to court orders, subpoenas or other legal processes by authorities with jurisdiction. SWC may disclose data to meet its obligations to health and drug regulators.
Business Transfer: SWC may transfer or assign your personal data as a result of, or in connection of a merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, liquidation or other business transaction.
8. Where is Data Stored?
The database and its contents remain at our company and stay with data processors or servers acting on our behalf and responsible to us.
Some of this data may be stored or processed at computers located in other jurisdictions, such as the United States and Europe, whose data protection laws may differ from the jurisdiction in which you live. Subject to applicable laws in such other jurisdictions, we will ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the data that are equivalent to those that apply in the country in which you live.
9. How Long Is Data Retained?
We only retain personal data for as long as is necessary for us to render a service you have requested or to which you have given your consent, except where otherwise provided by law (e.g. in connection with pending litigation).
Like many websites, SWC automatically collects technical data when you visit and use our website.
- Persistent cookies: may be used if you log on to restricted areas of our website to remember who you are. No personal data is stored on your computer.
- Session cookies: may be used for anonymous identification of a website visit for technical purposes only. Session cookies are stored only temporarily during the browsing sessions and are deleted once the browser is closed.
The data we collect could include information like region, age range, demographic, language, etc. to be able to provide you a more personalized experience and deliver content more relevant to your interests. While we do leverage the information we collect in aggregate to deliver more relevant advertisements and offers to you on other third party websites as you navigate the Internet, we do not share your personal information with any third party vendor or website owner for their own marketing purposes.
Most browsers are set-up to accept these cookies automatically. In addition, you can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer.
IP Addresses: We may collect your IP address when you visit our website to help us diagnose problems with our main computers, to administer the website and system, to report aggregated information to our partners, to assist in marketing practices, and to audit the use of our website. We do not normally link IP addresses to anything personally identifiable. In limited circumstances, we may use IP addresses to help us identify you when we feel it is necessary to enforce compliance with our General Conditions of Use or to protect our Services, website, users or others.
Analytics: SWC uses third party analytics service providers, such as Google and Adobe and other, to help better understand how visitors use our website. These technologies may record information such as how often you visit our website, which pages and features you frequent, aggregated use and performance data. This data may be aggregated and analyzed to help SWC provide you with a better online experience.
|Cookie(s):||Purpose and Content||Consent|
|Adobe Analytics:||Web analysis: These Cookies enable us to analyse your use of this website by assigning a unique and randomly generated ID to your device that lets us recognize your device upon your next visit.
Lifespan: 2 years
Provider: Adobe Systems Software Ireland Ltd.
|Google Tag Manager:||Web analysis: These Cookies enable us to analyse your use of this website by assigning a unique and randomly generated ID to your device that lets us recognize your device upon your next visit.
Lifespan: 6 months
Provider: Google Inc.
11. Interest Based Advertising
If you opted-in, we may collect certain information from you, including demographic, profile, region, contact, preference information. This information may be combined with technical data collected via cookies. Together, we may use this data to target advertisements to ranges of groups and demographics, using a third party service provider, such as Google DoubleClick. We do not collect or use health or other sensitive personal information for advertising or marketing purposes.
If you opted-in, we may share aggregated sets of data to a third party to assist in providing ads we feel may be relevant to you on third party sites. We do not share personal information to third parties for advertising, or for their own use. You may control your preferences or revoke consent to future participation in these analytics or marketing programs at any time.
Although it is our hope that you find the display of advertising to you based on your browsing interests valuable, if you no longer wish to participate in the services offered through these solutions, you can opt-out of this activity by visiting the:
i. Google DoubleClick: https://tools.google.com/dlpage/gaoptout/
ii. Network Advertising Initiative at http://www.networkadvertising.org/choices/, and
iii. Digital Advertising Association of Canada at http://youradchoices.ca/choices/.
See Section 15 – Your Options to learn what other choices you have.
12. How Is Data Kept Secure?
SWC uses technical and organizational security precautions to protect your data from manipulation, loss, destruction or unauthorized access, use, disclosure or alteration. Third parties that process personal data on our behalf are contractually obligated to safeguard data and only use the data provided to them for the purposes outlined in this Privacy Statement.
Our security procedures are continuously revised based on new technological developments.
In light of the importance of protecting children’s privacy, we do not collect, process or use on our website any information relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.
SWC does not intend this website for child audiences, and has no intention of collecting personally-identifiable information (such as name, address, telephone number) from children under 18 years old. If you discover that your child has provided us with personally identifiable information, we ask that a parent or guardian of the child contact us to have this information deleted from our records.
14. What About Third Party Links?
15. Your Options
Access and Update Requests: You have the right to review and amend any personal data stored in our system. Just send your request in writing to: [email protected]. SWC will provide you with access to your personal data that is in our possession, subject to certain exceptions, including data that is referenced to another individual’s personal information that we cannot sever, or information subject to solicitor-client privilege, or other legal restrictions that may prevent us from fulfilling your access request.
Interest based Advertising: If you no longer wish to participate in the services offered through these solutions, you can opt-out of this activity by visiting the:
iv. Network Advertising Initiative at http://www.networkadvertising.org/choices/, and
v. Digital Advertising Association of Canada at http://youradchoices.ca/choices/.
If you opt-out, please note you may still receive ads from SWC but they are not part of targeted advertising.
Opt-out of promotional communications: In the event you wish to unsubscribe from receiving promotional communications from SWC, you may opt-out by:
- Removing yourself by clicking “unsubscribe” at the bottom of an email we send you, or
- Contact us at: [email protected]
If you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, such as notifications regarding our business relationship with you, important notices regarding our Services, or as otherwise consistent with applicable law.
Right of Cancellation: You have the right at any time to withdraw your consent to the use of your personal data in the future. Again, just send an e-mail to the address given in the imprint or contact the Privacy Officer or the Data Security Officer at the information below.
16. Contact Us
If you wish to know what information we have in our files about you, ask a question about the information in your file or request a change to the information in your file, please contact:
TO BE DETERMINED
SWC may change certain parts to this Privacy Statement from time to time, so be sure to check this Privacy Statement regularly. Any changes to this Privacy Statement will be communicated promptly on this page. Please contact the website administrator with any problems, questions or suggestions that you may have. The constant development of the internet requires occasional adjustments to our privacy statement. We retain the right to make changes when necessary.