1.0 Introduction
In the course of conducting its business, Elvium Life Sciences Canada (“Elvium”) may collect, use and disclose personal information about members of the public, suppliers, service providers (“Service Providers”), physicians and other healthcare providers, patients and participants in clinical trials. To ensure that such personal information is appropriately and respectfully managed in compliance with the applicable privacy law in the various provinces of Canada in which it operates (“Canadian Law”), Elvium will adhere to the practices and procedures set out in this Privacy Statement as it may be updated and/or supplemented from time to time by notices, other policies, guidelines and rules relating to its management and protection of personal information (referred to collectively in what follows as the “Policy”).

By “personal information”, Elvium is referring to information in any format about an identifiable individual that it collects by any means, including electronically (“Personal Information”), including the individual’s name, home address and telephone number, email address, age, identification numbers, religion, racial and ethnic origin, credit and other financial information, and personal health information. Although Elvium also treats business information appropriately and respectfully, information about an individual in his or her professional capacity, including business contact information and information produced in the course of an individual’s business and used or disclosed for business purposes, is not covered by the Policy.

By providing your Personal Information to Elvium, or permitting someone else to do so, you are consenting to its collection, use and disclosure by Elvium in accordance with the Policy. If you do not agree to the terms of the Policy, please do not provide Elvium with your Personal Information or use its websites.

Elvium may update the Policy from time to time to reflect a change in its practices or Canadian Law. The date of the most recent revision will be posted at the top of the Policy and we ask that you review the Policy to see if it has been revised since the last time you communicated with us. Your continued use of one of our websites or disclosure to us of your Personal Information after the Policy has been revised will signify your acceptance of the revised terms of the Policy.

2.0 Scope of Policy
The Policy applies to the collection, use (which includes copying and processing), and disclosure of Personal Information by Elvium by any means, including electronically through www.elvium.ca and other Elvium websites (referred to collectively as the “Website”).

As a matter of convenience for users, the Website may contain links to websites that are not owned or operated by Elvium. The Policy does not apply to any website not owned and/or operated by Elvium or to the use and disclosure of Personal Information by the owners and operators of such websites. Elvium recommends that you review the policies and terms of use of such websites as they may differ from the Policy. Elvium will not accept responsibility for the collection, use or disclosure of Personal Information by the owners or operators of a linked website.

3.0 Accountability
Elvium’s Privacy Officer is responsible for Elvium’s compliance with the Policy, although other individuals within Elvium may be delegated related responsibilities.

Subject to Personal Information held by Service Providers, as described in section 6.0 below, Elvium generally stores Personal Information in Ontario, Canada, regardless of where it collects the information. Requests for access to an individual’s own Personal Information should be directed to Elvium’s Privacy Officer at the address provided in section 10.0 below.

Elvium will investigate complaints concerning its management of specific Personal Information or its Personal Information management practices. Complaints must be made in writing and addressed to the Privacy Officer, whose contact information is provided in section 10.0 below.

4.0 Consent
Under Canadian Law, Elvium is entitled to collect, use and disclose Personal Information without consent in a number of circumstances, including where an individual’s health, safety or security is threatened and in connection with an investigation into and/or the breach of a law or contract. Where Elvium requires consent to collect, use or disclose personal information, it may obtain that consent in any number of ways. If you have any questions about the meaning of the Policy or what we will do with your Personal Information, please consult our Privacy Officer.

As the use of Personal Information by employees and Service Providers is considered a use of the information rather than a disclosure of the information by Elvium, please note that Elvium does not require consent, beyond any that it required for its own collection, use and disclosure of the information, to share Personal Information with its employees and Service Providers.

5.0 Collection of Personal Information
Sources of Personal Information: Although, in general, Elvium collects Personal Information directly from the individual to whom it relates, Elvium occasionally requests Personal Information from other sources, for example, from an individual’s physician, health team or clinic (each a “third party”). Elvium will keep a record of the source of any Personal Information that it receives from a third party.

By providing Personal Information about another individual, you are representing that you have obtained that individual’s consent or are otherwise authorized to disclose the information to Elvium and Elvium will rely on that representation and will be not be responsible for any unauthorized disclosure you make to Elvium of Personal Information.

Electronic Collection: The Website uses “cookies”, data files that are sent and stored on the hard drive of a user’s computer, to collect information about traffic on the Website. The purposes for collecting such information, which includes the user’s internet protocol (“IP”) address, include to ensure that the content of the Website displays correctly on the user’s computer, to monitor and log traffic on different pages of the Website to assess interest in Website content, and to guide the design and content of the Website and related business decisions.  An IP address is a series of numbers assigned to a computer by the user’s internet service provider. An IP address may contain information that identifies a user. Elvium may link information that it collects electronically to Personal Information provided by an individual for the purpose of using certain tools or programs made available on the Website. Although you may be able to set your browser to reject cookies, some pages of the Website may not function properly if you do so.

Restricted Pages or Sites: Access to part or all of the Website may be restricted to healthcare providers or patients who have registered with Elvium, to meet legal requirements and/or because the content, tools or programs on the Website will be of particular interest to defined groups of healthcare providers or patients. Registration permits Elvium to authenticate users, control access and communicate with users and may also relate to a functional requirement of a particular tool or program.

6.0 Use of Personal Information
Elvium uses Personal Information to administer its business and the Website, including to: respond to inquiries and requests; monitor interest in information on the Website; assist in tailoring the content of the Website to the interests and needs of users; maintain, evaluate and improve the Website; provide information about its products; provide educational materials; compile statistics of interest and of assistance to healthcare providers and patients; make available tools and programs to assist healthcare providers to monitor and treat their patients and patients to be involved in their own care; authenticate and communicate with users of the Website; and, with consent, for marketing and research purposes.

Elvium may aggregate Personal Information to create statistical information that does not identify any particular individual and use the aggregated information to evaluate the use of the Website and make changes to it where appropriate, provide information of interest and assistance to heath care providers and patients, and for business purposes, including measuring the interest in particular products and/or topics.

Disclaimer Regarding Health Information: General information about health issues provided by Elvium, on the Website or otherwise, is provided for informational and/or educational purposes only and is not a substitute for medical advice, medical training, medical assessment or treatment for medical conditions. For individuals, the information is not intended to replace or override information and/or advice provided by an individual’s physician or other healthcare providers, and individuals are encouraged to consult a qualified medical or other healthcare provider before making any decision or taking any action that might affect their health.

Service Providers: Elvium uses Service Providers for various services, including processing and the storage of Personal Information and technical support for its electronic information systems. By contract, Elvium requires Service Providers to use appropriate security standards to protect Personal Information. Some of Elvium’s Service Providers operate outside of Canada, and more particularly, in the United Kingdom and Switzerland. Personal Information used by these Service Providers may be subject to the laws of their place of operation and available to its government and government agencies, among others, under those laws.

7.0 Disclosure
There are a number of circumstances in which Elvium is permitted or required by Canadian Law to disclose Personal Information without consent, for example, in response to a warrant, subpoena or order issued by a court, governmental or administrative authority with the power to compel the disclosure of the information and, as previously mentioned, where there is a threat to health, safety or security or in connection with an investigation into and/or the breach of a law or contract (including an investigation into suspected fraudulent, abusive or otherwise illegal activities). For example, Elvium may disclose information about an individual in connection with his or her use of the Website to law enforcement authorities for the purposes of an investigation. Elvium may also disclose Personal Information to protect or manage its rights and property, including in connection with any reorganization of its business or the evaluation of such a transaction, and in connection with obtaining insurance or making an insurance claim.

8.0 Security
Elvium uses a variety of means to safeguard Personal Information against loss, theft, unauthorized access, inappropriate disclosure, copying, use, modification or destruction, including technological means and enforcing compliance with the Policy.

Limited Access: Elvium has security policies and procedures that apply to access to and the use of its facilities and electronic information systems and equipment, including computers and mobile computing devices. Employees and Service Providers are permitted access to Personal Information to the extent that they require access for a purpose described in the Policy. It is prohibited for any employee or Service Provider to use Personal Information for his, her, its or a third party’s own purposes. Elvium takes seriously its responsibility to protect Personal Information and compliance with the Policy is a condition of employment or engagement with Elvium.

The Internet: As the Internet is not a secure means of transmitting information, users should not provide sensitive Personal Information, including sensitive personal health information, through the Website. Where you use passwords, ID numbers or other special access features on the Website, it is your responsibility to safeguard them.

9.0 Access and Correction
With limited exceptions, permitted or required by Canadian Law, Elvium will provide an individual with access to his or her Personal Information. Elvium will endeavor to process access requests in a timely manner.

Elvium will correct Personal Information that it determines is not accurate or complete and any unresolved differences will be noted and maintained with the relevant Personal Information.

10.0 Contact Information
Elvium’s Privacy Officer may be contacted at contact@elvium.ca or 3381 Steeles Avenue East, Suite 310, Toronto, ON M2H 3S7.

Last Revised: September 2020