PURPOSE

The Santen Canada Privacy Policy (hereinafter “Policy”) describes the manner in which Santen Canada Inc. (hereinafter “Santen”, “we”, or “us”) intends to collect, store, use and disclose the Personal Information (hereinafter “PI”) of Users who visit the Santen website (https://www.santencanada.ca/web/site/en/) (hereinafter “Santen website”), as well as general information regarding the collection, use, storage and disclosure of User PI in the context of Santen’s online activities.

We invite Users to carefully read the Policy, which sets out the manner in which Santen will process PI and qualifies the User’s individual rights and Santen’s obligations while engaging in the collection, use, storage, or disclosure of PI. By using the Santen website and Santen’s online services, including accessing content on the Santen website and submitting information to Santen’s online services, you are consenting to Santen’s practices and Santen’s use of your PI as described in this Policy.

Please note that Santen may at any time, and without notice, change, modify, add, remove or otherwise update the Policy by posting an amended Policy on the Santen website.

SCOPE

The Policy details the specific PI Santen collects, stores, uses and discloses, and the purposes for such collection, storage, use and disclosure of PI. The Policy will also detail the manner in which PI is utilized during the production of website-usage reports and which parties have access to User PI gathered by Santen. The Policy will delineate how PI is secured. Finally, the Policy will enumerate the User Rights to PI and how Users may exercise these rights.

DEFINITIONS

1. Cookie: A cookie is a small text file created by a website that is stored in the User’s computer either temporarily for that session only or permanently on the hard disk (persistent cookie). Cookies provide a way for the website to recognize you and keep track of your preferences.
2. User: Any natural person or legal entity that visits the Santen website, uses Santen’s online services, or to which a product or service offered by Santen is addressed
3. Personal Information (PI): Means information about an identifiable individual, including any representation of information that permits the identitiy of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Further, PI is defined as information: (i) that directly identifies an individual (e.g. name, address, social insurance number or other identifying number or code, telephone number, email address, etc.) or (ii) by which an agency intends to identify specific individuals in conjunction with other data elements, i.e. indirect identification (these data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors). Additionally, information permitting the physical or online contacting of a specific individual is the same as PI. This information may be maintained in either paper, electronic, or other forms of media.

PURPOSE OF COLLECTION, STORAGE, AND USE OF PERSONAL INFORMATION

1. Collection of PI. The majority of Santen’s online services do not require Users to conduct any manner of registration, allowing Users to visit the Santen website without directly disclosing PI. However, a select number of online services may require Users to directly provide PI, which may entail inputting direct identifiers into Santen website form fields, such as legal name, date of birth, email address, or telephone number.
2. Children. We do not knowingly collect, use, store or process Personal Information of Users who are under 18 years of age, without the consent of a parent or legal guardian. Santen’s website is intended solely for Users who are 18 years of age or older.
3. Santen may collect, store and use PI for the following purposes:
   • To provide the User with products or services;
   • To bill the User for products and services purchased online;
   • To market products and services which Santen believes are of interest to the User;
   • To adhere to local, provincial and Federal legal, regulatory, and security processing requirements;
   • To communicate with the User for other purposes, either evident from the circumstances or of which Users were notified at time of collection;
   • To enforce the legal terms that govern the Santen website or Santen online services;
   • To perform analysis regarding how Users use the Santen website and Santen’s online services and other User analytics;
   • To detect, prevent, mitigate and investigate fraudulent or illegal activities;
   • To customize or personalize content made available to Users based on their visits to and/or usage of the Santen website and Santen’s online services; and/or
   • For other purposes for which the User has provided consent.
4. Pharmacovigilance and Medical Inquiries. applies to one individual or multiple patients. The collection of PI is crucial to ensuring Any PI provided to Santen arising from the reporting of an adverse event or other activities related to pharmacovigilance and/or medical inquiries will be used solely for the purpose of addressing the report and/or request, as it public health and safety, and the use of PI collected for pharmacovigilance and medicial inquiry purposes will be limited to the detection, assessment, understanding and prevention of adverse effects or addressing any other medical concerns related to a Santen Product. Santen will collect and process PI in accordance with Santen policies, and local, provincial, and federal laws and/or regulations. The use of PI provided to Santen via a medical inquiry will be limited to the following purposes: (i) answering the inquiry, (ii) conducting necessary follow-up communication on the request; and (iii) maintaining the PI in a secured Medical Information Database for the purpose of responding to future inquiries and/or adverse events. Where required by law, Santen will disclose PI to regulatory authorities, limited to only the minimum information necessary to comply with the legal requirement.
5. Cookies. Santen may collect, store, use and process information about a User’s visit to the Santen website, such as the pages visited, the website the User arrived from, and any relevant searches the User performs. Such information is used by us to help improve the contents of the site and to compile aggregate statistics regarding site use for internal and market research purposes. To further this aim, we may install Cookies that collect information, including the User’s domain name, internet service provider, operating system, as well as the date and time of access. Cookies do not damage your computer. You can set your browser to notify you when you receive a Cookie, as this will enable you to decide whether to accept or reject it. Keep in mind that rejection of Cookies may limit your access to functionalities of your browser software. We may also use external service providers to help us collect, store, use and process the information described in this section.
6. Internet Tags, Third Party Data Collection. Occasionally, we may use internet tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) and Cookies, deployed through a third-party advertising partner or web analytical service partner, who may store the collected data (including your IP-address) in a foreign country. Tags and Cookies exist within online advertisements that bring Users to the Santen website.

   This technology measures the effectiveness of Santen’s advertising campaigns as well as to evaluate User use of our website.

   Via the tags and/or Cookies, a third-party or web analytical service partner may collect visitor data. The collection and use of this data would be solely for the purpose of generating website activity reports for Santen.

   Our third-party partners are entitled to disclose collected User information only where there is a legal obligation to do so, or if they hire subcontractors to process information on their behalf. If you would like more information about internet tags and Cookies associated with online advertising, please visit the Network Advertising Initiative (www.networkadvertising.org).

7. Google Analytics. We use Google Analytics to rationalize our portfolio of websites by: (i) optimizing traffic to and between corporate websites; and (ii) integrating and optimizing web pages where appropriate. Google Analytics is a service offered by Google, Inc. that generates detailed statistics about a website's traffic and traffic sources and measures conversions and sales. Google Analytics uses Cookies stored on your computer to help analyze how users use our website. Any PI generated will be anonymized prior to being transmitted to Google’s U.S. servers. For more information on how IP anonymization works, please see: https://support.google.com/analytics/answer/2763052.

   You may prevent the installation and storage of Cookies by downloading and installing the free Opt-out Browser Add-on available at: https://tools.google.com/dlpage/gaoptout?hl=en.

   If you do not accept Cookies, you may not be able to fully experience the functionality of the Santen website. Google may transfer this information if legally obligated or if a third party processes the information on Google's behalf. By using our website, you consent to the processing of any PI that Google collects about you in the manner and for the purposes described above.

DISCLOSURE, ACCESS AND TRANSFER OF PERSONAL INFORMATION

We will not sell, share, or otherwise distribute your PI to third parties for any purpose except as provided in this Privacy Policy. We may share your PI with other Santen affiliates worldwide.

PI may also be transferred to third parties whom we have contracted to act for or on our behalf, for further processing in accordance with the purpose(s) for which the data were originally collected or may otherwise be lawfully processed. These purposes include services delivery, evaluating the usefulness of this website, marketing, data management, and/or technical support.

PI collected from you may be transferred to a third party in the event that the business (in part or in whole) and User data is sold, assigned, or transferred, in which case Santen would require the buyer, assignee, or transferee to treat PI in accordance with the terms of this Policy.

PI may be disclosed to a third party if Santen is required to do so because of an applicable law, court order, or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding in Canada or abroad.

In addition, Santen may disclose to a third party anonymized and/or aggregated information which does not allow you to be personally identified to third parties.

The PI we collect from you may also be processed, transferred, accessed, or stored in countries outside of Canada. Such countries may have different standards for securing and storing PI. Any such transfer will be conducted in compliance with applicable laws and regulations, and PI may be subject to the local laws of the jurisdictions within which it is transferred. Such local laws may require that your PI to be disclosed to government agencies and/or law enforcement agencies under different circumstances than would Canada. By using the Santen website and Santen’s online services, you consent to such transfer of your PI to countries outside of Canada.

SECURITY MEASURES

To protect the security and confidentiality of PI collected online by Santen, we use data networks protected by industry-standard firewall and password protection systems. When handling your PI, we take measures reasonably designed to protect from loss, misuse, unauthorized access, disclosure, alteration, destruction, and other unlawful forms of processing.

No internet transmission is, however, 100% secure or error-free. It is, your personal responsibility to ensure that the computer you are using is adequately secured and protected against malicious software, such as trojans, computer viruses, and worm programs. You are aware of the fact that without adequate security measures (e.g. secure web browser configuration, up-to-date antivirus software, personal firewall software, no usage of software from dubious sources) there is a risk that the data and passwords you use to protect access to your data, could be disclosed to unauthorized third parties.

RETENTION AND DISPOSAL OF PERSONAL INFORMATION

1. Retention of Personal Information.

   Any Personal Information collected by Santen shall only be retained as long as necessary for the purposes for which it was collected or for which consent was received, unless otherwise required by law. Also, Santen will retain your information for any new purposes identified by us and consented to by you, for any appropriate time thereafter. The length of time we will store PI will differ, depending on the purpose for which we have collected and are processing the data. Personal Information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous. However, we may maintain data for a longer period if legally required to do so.

2. Disposal Methods. Upon expiration of the retention period, Santen will delete the PI, using industry-standard methods that resist simple recovery methods, such as data recovery utilities and keystroke recovery attempts. Santen will adhere to applicable law and the NIST Guidelines for Media Sanitization (https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-88r1.pdf) when disposing of PI. Santen may retain a third party to assist with the disposal of PI. All third party contractors will have verifiable credentials and will be contractually bound to guarantee both a secure transfer of records and destruction method appropriate to the information sensitivity.

PRIVACY POLICY UPDATES AND CONSENT

This Privacy Policy will be updated as required to reflect new services, programs or changes in our privacy practices. Whenever we revise this Policy, we will update our website to inform you of the change. We reserve the right to change our privacy information practices and the terms of this Policy at any time without notice, and to apply the changed practices to all information we have about you by posting an amended Policy on the Santen website. Please refer back to this Policy periodically for any updates or changes.

By using any of the Santen online services, you are consenting to the terms of this Privacy Policy as stated at any time you use it. You may withdraw your consent at any time by contacting our Privacy Officer, unless legal requirements prevent this. If you choose to withdraw your consent, we may not be able to provide or to continue to provide certain services or information to you.

ACCESSING AND UPDATING PERSONAL INFORMATION

Subject to certain legal exemptions, you have the right to request and review any of your Personal Information we may currently have about you. You may update your Personal Information that you have provided to us for accuracy. We will take reasonable steps to make sure that any updates that you provide us are processed in a timely and complete manner.

CONTACT US

If you wish to contact Santen regarding our use of your Personal Information or you wish to exercise your data privacy rights, please contact our Privacy Officer by email at Privacy-Canada@santen.com or write to:

Santen Incorporated
Attn: Privacy Officer
6401 Hollis Street, Suite 125
Emeryville, California 94608, U.S.A.

If you contact us, please include the following information in your email, so that we may efficiently respond to your request and so that we may identify you and the subject of your request:

• the name of the website your inquiry is referring to;
• your relationship and/or interactions with us (as applicable); and
• the specifics of the information you would like us to provide or you want us to take action upon.