Last Updated: September 11, 2018
NEOSTRATA® of Canada collects personal information for a variety of purposes relating to the operation of our business and the delivery of services to you, so you can benefit from specified features or promotions, or participate in a particular activity. For example, we collect information in order to:
- provide our products and services and generally manage and administer our business including maintaining business records for reasonable periods and defending and bringing legal actions;
- develop and improve our products and services;
- develop and implement brand and consumer marketing programs and services that specifically tailor consumer offers or communications to your specific needs based on personal information that you have provided to us that indicates such things as your product or purchasing preferences or requirements;
- administer contests, promotions and marketing services, surveys and web site chat rooms or applications and social media forums (e.g. Facebook wall posts) or any other web or mobile applications;
- administer consumer satisfaction surveys to obtain feedback to improve the products and services we provide you;
- provide you with health and product-related information;
- reply, fulfill or to clarify your requests, inquiries and comments;
- receive and assess product inquiries, reports of adverse events, and product complaints;
- assist in or co-ordinate product recalls;
- establish and maintain our relationship with health care professionals and administrators and other individuals with whom we have contact in the course of our business;
- provide assistance and advice to health care professionals and institutions with respect to our products;
- test and analyze our products for efficacy and safety;
- meet legal, regulatory, insurance, security, ethical and processing requirements such as adverse event and clinical reporting to Health Canada and regulatory bodies;
- monitor compliance with informed consent requirements when patients participate in clinical trials, and verify that clinical data collected by NEOSTRATA® of Canada in the course of the clinical trial conforms to the source data available at the site of the clinical trial;
- use feedback provided to us in the course of advisory board meetings to develop the strategic positioning of our products;
- manage, administer, collect and enforce accounts;
- provide remuneration to individuals who have performed services for NEOSTRATA® of Canada;
- enable us to act responsibly in the event of a health or other crisis or emergency and to enhance workplace security;
- evaluate resumés or other personal information submitted to us in connection with employment possibilities. For candidates who are not offered or do not accept a position, we may retain their information in the event that an appropriate position becomes available or that they re-apply to NEOSTRATA® of Canada.
- conduct analysis for our business purposes, such as audits, developing new products, enhancing our website, improving our products and services, identifying Site usage trends, personalizing your experience on the Site by presenting products and offers tailored to you, and determining the effectiveness of our promotional campaigns.
NEOSTRATA® of Canada will limit the collection and use of both the amount and the type of personal information to that which is necessary to fulfill the identified purpose at the time of collection or as identified above.
We may also use your personal information for other purposes that are disclosed at the time of collection with your consent or as permitted or required by law. You will be informed what information is required and what information is optional.
Information You Provide
Some areas of the Site may ask you to submit personal information in order for you to:
- purchase a product directly from us;
- interact with our Web sites or our mobile apps;
- participate in social media forums, or post information on bulletins, sponsored blogs or on our web sites;
- otherwise provide your personal information to us, including by telephone, mail, email, facsimile, through any of our Web sites, by chat application or by SMS/text messaging or other electronic means.
The information we may collect includes:
- personal and business contact information, such as name, title, address, telephone number and email address;
- name, address, age, recorded information (such as a video), photographic images, in connection with promotions such as contests;
- consumer preferences and consumer comments about our products and services;
- names and other contact details of consumers who use our products and their physicians and, in certain circumstances, sensitive health information, and patient medical history, for example, where we have received a report of an adverse event, or where we are assisting in or conducting product recalls;
- information collected in connection with inquiries or comments made by individuals who contact our consumer care centre;
- names and other contact details of physicians participating in advisory boards and the opinions or comments expressed by those physicians during advisory board meetings;
- names and other contact details of physicians involved in running clinical trials, together with their professional information such as curriculum vitae and other information that is required to be reported to Health Canada and other regulatory bodies;
- information such as name, age, and gender of patients participating in clinical trials together with the clinical data collected in the course of the clinical trials. NEOSTRATA® of Canada generally receives patients' clinical data that has been recorded using identifiers other than the patients' full name, such as the patients' initials. More comprehensive patient data, including full names, may be reviewed by our clinical site managers when they attend at the trial site for compliance monitoring;
- information from individuals visiting our premises such as their name and the name of the organization for which they work or which they represent. We may also post video cameras in public-access areas on our premises;
- user names used by consumers on social media sites and comments/questions associated with those sites; and
- other information with your consent or as permitted or required by law.
Calls to and from NEOSTRATA® of Canada may be recorded and/or monitored for quality and training purposes. Recordings may also be used to help us develop and improve our products and services. Information may also be actively and passively collected by our Web sites. See Technology Implications below for details.
We may combine the information you submit with other information we have collected from you, whether online or offline, including, for example, your purchase history. We may also combine it with information we receive about you from other sources, such as other Johnson & Johnson operating companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.
Passive Information Collection and Use
As you navigate around a Site, certain information can be passively collected (that is, gathered without your actively providing the information), using various technologies. We and our third party service providers may passively collect and use information in a variety of ways, including:
Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access a Site through a mobile device.
You can refuse to accept these cookies by following your browser’s instructions; however, if you do not accept them, you may experience some inconvenience in your use of the Site. You may also not receive advertising or other offers from us that are relevant to your interests and needs. To learn more about cookies, please visit http://www.allaboutcookies.org.
Using Flash cookies: Our use of Adobe Flash technology (including Flash Local Stored Objects ("Flash LSOs")) allows us to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the Site, and collect and store information about your use of the Site. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Site or our online content.
Using pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages and HTML-formatted e-mail messages to, among other things, track the actions of Site users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about Site usage and response rates.
IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
Device Information: We may collect information about your mobile device, such as a unique device identifier.
How We Disclose Information
We also disclose information collected through the Site:
- to our third party partners with whom we have contracted to offer co-branded or co-marketed promotions and/or services;
- in order to meet legal, regulatory, industry self-regulatory, insurance, audit, security or ethical requirements, including obligations to health and drug regulatory and self-regulatory bodies, physicians, hospitals, or other health care facilities;
In addition, we use and disclose information collected as we believe to be necessary or appropriate: (a) as permitted or required by applicable law or court order, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose information collected in other ways, with your consent.
We also use and disclose information we collect passively as described above, under "Passive Information Collection and Use," and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.
Disclosures - Use of Service Providers
We may transfer personal information to outside agents or service providers as described above. Some of these service providers may be located outside of Canada, including in the United States. While outside of Canada, your personal information will be subject to applicable foreign legal requirements, which may include lawful requirements to disclose personal information to government authorities in certain circumstances. We take contractual or other means to ensure that your personal information that may be collected, used, disclosed, accessed, stored or otherwise processed by the service provider on our behalf is protected and not used or disclosed for purposes other than directed by us, subject to legal requirements in foreign jurisdictions applicable to those organizations.
Please refer to the CONTACT US access, change, or delete section below in order to find out how to obtain access to written information about our practices with respect to: disclosures and/or service providers outside of Canada and the title of the person who is able to answer, on behalf of NEOSTRATA® of Canada, questions you may have about a) the service providers outside Canada who may collect, use, disclose, access, store your personal information, b) the purposes for collecting, using, disclosing, accessing or storing your personal information, or c) where information will be held or the categories of persons who will have access to it.
We may also disclose your personal information in other circumstances with your consent.
THIRD PARTY SITES AND SERVICES
We use reasonable organizational, technical, and administrative measures to protect personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contact Us" section below.
CHOICES, CONSENT AND ACCESS
Your choices regarding our collection, use and disclosure of your personal information:
We give you choices regarding our collection, use and disclosure of your personal information for marketing purposes. In some cases you will, at the point of collection of the information, be given the option to "opt in". The act of "opting in" constitutes your express consent to receive future communications that may be of relevance to you. You can provide your express consent to our collection, use and disclosure of such information by checking a box on a form, clicking on a specified icon on a web site, or by doing some other specified express action such as contacting us by telephone or by e-mail, or by signing a consent form on which your personal information is requested. Your personal information will in such case only be collected, used or disclosed for the purposes we describe at that time if you "opt in". You will, for example, have the option to "opt in" to receive information about, or special offers for, the products of NEOSTRATA® of Canada, in which case you will receive information relating to those brands and programs of NEOSTRATA® of Canada that we believe may be of interest to you. By "opting in" to offers from NEOSTRATA® of Canada, you are indicating your agreement to automatically receive communications regarding any brands or programs of NEOSTRATA® of Canada that we believe will be of interest to you. Alternatively, for certain brands or specific programs, where offered, if you wish to receive information relating only to specific brands and related programs or only to specific programs, you will have the option to "opt in" separately for these. After you "opt in" to receive offers or programs, you will have the option to "unsubscribe" or withdraw your consent if you no longer want to receive communications, either by following the instructions in an e-mail we send you or by contacting us by other means, as described below.
It is currently our policy, when collecting personal information that will be input into the NEOSTRATA® of Canada consumer database, to only use that information for the purpose(s) identified at the time of collection as described above. Unless you have indicated that you wish to receive specific program or brand information the information you provide will not be used to send you offers and communications outside of the initial interaction (e.g. registration, trial offer, contest, or coupon request).
When you wish to participate in a promotion, contest or survey, engage or participate in discussions, promotions or otherwise interact on our web sites, or to purchase a product you will not be required, as a condition of your participation or purchase of the product, to provide more personal information than is necessary or legally required in order for us to administer the promotion, contest or survey, facilitate the discussion or to deliver any products you may be entitled or wish to receive. However, you may be provided with the option of providing additional personal information. You may, for example, choose to provide additional personal information by completing a questionnaire on a contest ballot or a personal profile relating to your use of our products or provide household information, in which case we may then use that information to assist us in developing, improving, and selling our products or improve your interactions on our web sites.
If you have provided us with personal information and wish to withdraw your consent to its retention, use or disclosure, you may opt out from receiving marketing communications from us. If you no longer want to receive marketing communications from us on a going-forward basis, you may opt out of receiving them by: either following the unsubscribe instructions provided within any marketing communication; or by contacting us via the methods described below. In your response to us, please provide your name, identify the form(s) of marketing communications that you no longer wish to receive, and include the address(es) to which it/they are sent. For example, if you no longer wish to receive marketing e-mails or direct mail from us, tell us that, and provide your name and e-mail or postal address. In any case, we will seek to comply with your request(s) to unsubscribe from marketing communications as soon as reasonably practicable in accordance with applicable privacy laws.
You may contact us as described below in order to:
- Request to withdraw your consent to our retention, use or disclosure of your personal information;
- Request access to or correction of your personal information;
- Receive information or special offers;
- Obtain access to written information about our practices with respect to service providers outside of Canada or get answers to questions you may have about a) the service providers outside Canada who may collect, use, disclose, access, or store your personal information, b) the purposes for collecting, using, disclosing, accessing or storing your personal information, or c) where information will be held or the categories of persons who will have access to it;
- Requests regarding item 4 above must be made in writing. Requests are subject to some access exceptions as prescribed by law and identified below under Access Exceptions. Any exceptions to providing you with access to your personal information must be approved by the Canadian Chief Privacy Officer.
How you can access, change, or delete your personal information:
If you would like to review, correct, update, or delete the personal information that you have provided via a Site, please contact us:
By writing to us at the following address:
NEOSTRATA® of Canada Consumer Care Centre
Canadian Chief Privacy Officer
88 McNabb St
Markham, ON L3R 4N6, Canada
By telephone at the following toll-free number: 1-800-265-8383 and ask to speak to the Canadian Chief Privacy Officer;
or By email to us via our contact us online form
We will seek to comply with your request(s) as soon as reasonably practicable in accordance with applicable privacy laws. Please also note that if you opt out of receiving marketing-related messages from us, we may still send you important transactional and administrative messages, from which you cannot opt out in accordance with applicable laws.
Some information may not be accessed in certain limited circumstances. In some cases, for example, the following exceptions may apply to information:
- that contains references to other individuals and such information is not severable from your personal information,
- the disclosure of which would reveal confidential commercial information, and
- that is subject to solicitor-client or litigation privilege.
The Canadian Chief Privacy Officer must approve all exceptions to access. The reasons for denying access shall be provided by NEOSTRATA® of Canada upon request.
USE OF SITE BY MINORS
Our Sites are not directed to individuals under the age of 13, and we request that these individuals not provide Personal Information through a Site unless expressly stated and with parental consent as instructed on the Site. If a child under 13 has provided us with personal information, we ask that a parent or guardian of the child contact us 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. We encourage parents to talk to their children about their use of the Internet and the information they disclose to web sites or otherwise.
Your personal information may be stored and processed in any country where we have facilities or service providers, and by using a Site or by providing consent to us (where required by law), you agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country.
Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through a Site or otherwise to us. In those cases where we may request or invite you to provide sensitive information, we will do so with your express consent.