Nadurel Pharma Inc. (“Nadurel” also referred to as “we” or “us”) collects, stores, and processes information relating to any identified or identifiable individual (“Personal Information”) to manage our business and maintain commercial relationships. Nadurel has developed the present privacy notice (the “Notice”) to govern the processing, notably the collection, use, disclosure, retention, and destruction of Personal Information in compliance with the Privacy Laws. This Notice describes how Nadurel processes the Personal Information, and the data protection rights from which you benefit.
Nadurel is the responsible controller for the Personal Information it processes and has appointed a Chief Privacy Officer (“CPO”) to oversee Nadurel’s compliance with the Privacy Laws. Contact details of responsible controller : Nadurel PHARMA INC., 4395 Beaudry, St-Hyacinthe, Québec, Canada, J2S 8W2, T: (877) 421-8193|E: info@Nadurelpharma.ca
Nadurel collects and processes the following Personal Information:
- Identity and Contact Data, including your name, address, telephone number, date of birth, marital status, employment history, educational or professional background, tax status, employee number, job title and function, and other Personal Information concerning your preferences relevant to our business;
- Financial Data, including your bank account and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
- Business Information, including information provided in the course of the contractual or client relationship between you or your organization and Nadurel;
- Profile and Usage Data, including passwords to Nadurel websites or password protected platforms or services, your preferences in receiving marketing information from us, your communication preferences and information about how you use our website including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs).
- Technical Data, including information collected during your visits to our website, the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating systems and platforms.
- Physical Access Data, relating to details of your visits to our premises.
Purposes of Collection
Nadurel collects your Personal Information to manage its business and to maintain and develop commercial. Nadurel will collect, use, and disclose such information only to the extent that is necessary for those purposes. If Nadurel is required to use or disclose your Personal Information for a different purpose, Nadurel will obtain your consent before using or disclosing the Personal Information.
Nadurel will only provide you with marketing related information after you have, where legally required to do so, opted in to receive those communications and having provided the opportunity for you to opt out at any time. Nadurel will not use Personal Information for a purpose other than for which it was collected except with your consent unless: (a) legal, medical or security reasons make it impossible to obtain consent; or (b) Nadurel is permitted or required to do so by applicable laws.
How Nadurel Collects Personal Information
The circumstances in which Nadurel can collect Personal Information about you include:
- when you or your organization purchases our products;
- when you or your organization offers to provide, or provides, services to us;
- when you correspond with us by phone, email or other electronic means, or in writing, or when you provide other information directly to us,;
- when you or your organization browse, complete a form or make an enquiry or otherwise interact on our website or other online platforms;
- when making enquiries about your organization, other organizations with whom you have dealings such as former employers and educational institutions, or from third-party sources such as government agencies, a credit reporting agency, information service providers or from publicly available records.
Nadurel limits the Personal Information it collects to what is necessary for managing its business and maintaining and developing its commercial relationships.
Third Party Information Collection
Nadurel will collect your information from third parties, where Nadurel has obtained the requisite consent to do so or as otherwise permitted by law. From time to time you may provide Nadurel with the Personal Information of individuals other than themselves. You agree to obtain, prior to disclosing such information to Nadurel, the knowledge and consent of each individual to the disclosure, and to subsequent use by Nadurel, of such Personal Information, in accordance with this Notice, unless otherwise permitted by law.
Data Processing While Using Our Website
Information Collected from your Use of the Site
Social Media Widgets
Nadurel’s internet site may include widgets, such as the “Share This” button or interactive mini-programs that run on Nadurel’s internet site.
Links to Third-Party Sites
Nadurel’s internet site includes links to other internet sites, the privacy practices of which may differ from those of Nadurel.
Disclosure and Retention
Disclosure of your Personal Information
Nadurel shares your Personal Information only with third parties including certain service providers we have retained in connection with the commercialization of our products.
Collection, Use, Disclosure and Storage Outside of Canada
Nadurel, its third-party service providers and other third parties to whom Nadurel discloses information under the Notice may perform activities outside of Canada. Any Data Subject’s Personal Information that is used, stored or accessed in countries outside of Canada may be subject to the laws of those countries. As a result, Personal Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement officials in countries outside of Canada. You may seek additional information regarding the collection, use, disclosure or storage of their Personal Information outside of Canada by contacting Nadurel’s CPO.
Nadurel will not retain Personal Information longer than is necessary to fulfill the purpose for which it was collected including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for Nadurel to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. As this purpose varies depending upon the Personal Information involved, Nadurel invites concerned You to contact Nadurel’s CPO for any inquiries pertaining specifically to them.
Upon expiry of the applicable retention period we will securely destroy your Personal Information in accordance with applicable laws and regulations and with Nadurel’s Document Retention Policy.
Nadurel uses reasonable efforts to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. Nadurel will not routinely update your Personal Information, unless such a process is necessary. In order to help Nadurel maintain and ensure that your Personal Information is accurate and up to date, you must inform Nadurel, without delay, of any change in the information they provided to Nadurel.
Nadurel is committed to protecting the confidentiality, integrity, availability and privacy of your Personal Information. Nadurel employs security safeguards that are customary in the healthcare product industry and appropriate to the sensitivity of the information, including physical, organizational, and technological measures.
Nadurel is committed to being transparent about its policies and invites you to contact the CPO with any questions they may have or to visit Nadurel’s website.
You have various rights with respect to our use of your Personal Information, these include:
- Access: You have the right to request a copy of the Personal Information that we hold about you. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal Personal Information about another person, or if we are legally prevented from disclosing such information. You are entitled to see the Personal Information held about you.
- Accuracy: We aim to keep your Personal Information accurate, current, and complete. We encourage you to contact us using our contact form to let us know if any of your Personal Information is not accurate or changes, so that we can keep your Personal Information up-to-date.
- Objection: In certain circumstances, you also have the right to object to processing of your Personal Information and to ask us to block, erase and restrict your Personal Information. If you would like us to stop using your Personal Information, please contact us.
- Right to restriction: You have the right to obtain from Nadurel the restriction of processing in some circumstances.
- Portability: You have the right to request that some of your Personal Information be provided to you, or to another data controller, in a commonly used, machine-readable format.
- Erasure: You have the right to erase your Personal Information when the Personal Information is no longer necessary for the purposes for which it was collected, or when, among other things, your Personal Information has been unlawfully processed.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts.
Access to Information
You may enquire about their Personal Information by contacting the CPO or making a request to view their information at info@Nadurel.ca.
Right to Withdraw Consent
If you have provided your consent to the collection, processing or transfer of your Personal Information, you have the right to fully or partly withdraw your consent.
Any report, concern, complaint or incident of which Nadurel becomes aware that involves conduct that may contravene the Notice will be treated confidentially to the extent possible. However, some disclosure may be necessary to adequately address issues raised, aid enquiry and implement solutions, as appropriate. Nadurel takes all potential or actual privacy breaches seriously. You may report your concerns about the collection, use, disclosure, retention or destruction of your Personal Information directly to Nadurel’s CPO. The CPO will engage the appropriate levels of management to assist with a resolution of the issue.
MONITORING/ OVERSIGHT MECHANISM
The Nadurel Data Protection Committee (“DPC”) conducts periodic reviews of incidents and issues raised through the Incident Reporting and Escalation Process to identify and address systemic issues.
ROLES AND RESPONSIBILITIES
Nadurel is responsible for communicating this Notice and ensuring that members of the Nadurel team fully comply with all relevant aspects of this Notice and the accompanying guidelines.
Business and Infrastructure Units
Business or infrastructure units that collect, use, or disclose your Personal Information, other than as required, are responsible for ensuring that these activities comply with the Notice. This includes addressing requirements for the collection, use, disclosure, retention, and destruction of Personal Information.
Nadurel Chief Privacy Officer (CPO)
Nadurel’s CPO is responsible for overseeing Nadurel’s DPC, which manages Nadurel’s privacy-related risks and supports the protection of privacy and confidentiality of all You Personal Information. The CPO provides support through the DPC Incident Reporting and Escalation Procedures and general awareness and education. The CPO serves as Nadurel’s official liaison with the federal and provincial Privacy Commissioners.
The DPC is responsible for providing legal advice and direction to the CPO, as necessary to support appropriate handling of access requests and privacy complaints.
MAINTENANCE AND REVIEW
This Policy is effective as of September 1, 2023, and supersedes all prior versions. Nadurel reserves the right to interpret the Policy at its sole discretion and to make changes as it deems appropriate from time to time without the requirement of advance notice.
Privacy Laws continues to evolve and, as a result, this Policy may be amended by Nadurel from time to time at Nadurel’s full discretion without any prior notice or liability to you or any other person. The collection, use and disclosure of your Personal Information by Nadurel will be governed by the version of this Policy in effect at that time.