Last Updated: July 4, 2023
We Value Your Privacy
JAMP Pharma Corporation (“JAMP” also referred to as “we” or “us“) collects, uses, and discloses (“Processes”) information that directly or indirectly identifies you or another individual (“Personal Information”) when you purchase our goods and use our services. We have developed the present privacy notice (the “Notice“) to communicate how and why we Process your Personal Information as well as how we protect your rights and respond to your requests concerning this information.
1. Q: Who is responsible for Processing my Personal Information?
JAMP is responsible for the Personal Information we Process. We undertake to Process it in compliance with the data protection laws applicable to the jurisdictions in which we conduct our activity. We have appointed a Chief Privacy Officer (“CPO“) to oversee our compliance with these laws and to answer any questions you may have about how we Process your Personal Information or how to exercise your rights concerning this information.
Our contact details as well as those of our CPO are the following:
1.1 Contact Details
JAMP Pharma Corporation
1310 Nobel Street
Boucherville, QC J4B 4H3
Attention: Chief Privacy Officer (email@example.com)
2. Q: What Personal Information does JAMP Process?
JAMP Processes the following Personal Information:
(a) Identity and contact information: including your name, address and telephone number. If you apply for employment via our internet site we will also Process information typically contained in an employment resumé such as employment history, education, and professional background.
(b) Profile and usage information: including passwords to our website(s) 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(s) 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).
(c) Technical information: including information collected during your visits to our website(s), the Internet Protocol (IP) address, or Media Access Control (MAC) address if you are accessing our site from a mobile device, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating systems and platform.
(d) Physical access information: relating to details of your visits to our premises.
3. Q: Why does JAMP Process my Personal Information?
JAMP Processes your Personal Information to manage our business and to maintain and develop our commercial relationships as described further on. We only Process such information that is necessary for those purposes. If we are required to Process your Personal Information for a purpose that differs from the purposes described herein, we will obtain your consent before doing so except in those circumstances set out in Section 5 of the Notice.
The purposes for which we collect your Personal Information are as follows:
(a) To execute any obligations arising from a contract entered into between us and you. This includes:
(i) to register you as a client and manage your account;
(ii) to provide and administer our services or other services or solutions, as instructed by you; and
(iii) to recruit and Process applications for employment.
(b) As required by us to conduct our business and pursue our legitimate interests in particular:
(i) to provide our services and to respond to and address any questions or concerns relating to our services;
(ii) to analyse and improve our services and communications including our internet site operations and to monitor compliance with our policies and standards;
(iii) to manage access to our premises and for security purposes;
(iv) to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
(v) for insurance purposes; and
(vi) to collect information about your preferences to personalize our communications with you.
(c) As required by us to conduct marketing or other promotional activity including:
(i) to communicate promotional material that you have requested and to which you may unsubscribe by clicking on the Unsubscribe link or following the Unsubscribe instructions included in every mail; and
(ii) to support you in your participation in our marketing programs or events.
(d) As required to comply with any legal duties or to take legal action including:
(i) to protect our rights and safety as well as that of any third parties;
(ii) to comply with any legal requirements or court orders;
(iii) to prosecute and defend a court, arbitration, or similar proceeding; and
(iv) to communicate this information to any advisors who assists us in complying with legal, accounting, or security requirements.
(e) as otherwise permitted by law.
JAMP will only send you marketing related information after you have, where legally required to do so, opted to receive such information and have been provided the opportunity to opt out at any time.
JAMP will not use your Personal Information for taking any automated decisions affecting or creating profiles other than as described above.
JAMP 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) We are permitted or required to do so by applicable laws.
4. Q: How does JAMP collect my Personal Information?
4.1 Directly from you
JAMP collects your Personal Information directly from you and with your consent in the following circumstances:
(a) when you purchase our products, solicit our services, or share your Personal Information on our internet site;
(b) when you enquire about our products;
(c) when you correspond with us by phone, email or other electronic means, or in writing, or when you provide other information directly to us, including in conversation with our employees;
(d) when you browse, complete a form (including information reporting a problem with the internet site) or make an enquiry or otherwise interact on our website or other online platforms you are willingly providing information which could be included in the collection of Personal Information. Depending on the circumstances, this may include Personal Information such as, but not limited to, physical mailing address, personal email address, phone number(s), and other details like gender, occupation, and other demographic information. More information on how our website Processes Personal Information can be found in section 4.3 below; and
(e) when you attend our seminars or other events or sign up to receive information from us.
Where we need to collect Personal Information by law or in order to Process your instructions or perform a contract we have with you and you fail to provide that Personal Information when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
4.2 Indirectly from a third party
Sometimes JAMP collects Personal Information about you from a third party. In such instances we will provide you with the following information:
(a) our name and contact details and, where applicable, those of our representative;
(b) the contact details of our CPO;
(c) the purposes of the Processing for which the Personal Information is intended as well as the legal basis for the Processing;
(d) the categories of Personal Information concerned and methods used to collect it;
(e) the recipients or categories of recipients of the Personal Information if any;
(f) where applicable, our intention to transfer Personal Information to recipients in other countries, a description of the appropriate or suitable safeguards put in place to protect such Personal Information, and how you can obtain a copy of the Personal Information or the location where is has been made available;
(g) the period for which the Personal Information will be stored, or if that is not possible, the criteria used to determine that period;
(h) whether the Processing is based on our legitimate interests or on those of a third party;
(i) the existence of the right to request from us access to and/or rectification, cessation of dissemination, de-indexation, re-indexation, and/or mobility of your Personal Information;
(j) the existence of the right to withdraw consent at any time, without affecting the lawfulness of Processing based on consent before its withdrawal; and
(k) the source of the Personal Information, and if applicable whether it came from publicly accessible sources.
JAMP is not required to provide you with the aforementioned information if:
(a) you already have the information;
(b) the communication of such information proves impossible or would involve a disproportionate effort;
(c) the disclosure is expressly forbidden by the law to which we must comply and which provides appropriate measures to protect your legitimate interests; or
(d) the Personal Information must remain confidential subject to an obligation of professional secrecy regulated by law.
4.3 Using our internet site
When you visit or interact with JAMP’s internet site we may collect your information in the following manner.
4.3.1 Cookies and web beacon pixels
Our email marketing communications may contain a single, campaign-unique “web beacon pixel” to tell us whether our email is opened and combined with other technology verify any clicks through to links within the email. We may use the information for purposes including determining which of our email is more interesting to you and to query whether users who do not open our email wish to continue receiving them. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, through email you can opt not to download images from JAMP.
You may also choose not to click in the email marketing communications that we send you. This information may be connected to your personal identity.
4.3.2 Social Media Widgets
4.3.3 Third party internet sites
JAMP’s internet site includes links to other internet sites, the privacy practices of which may differ from ours. If you submit Personal Information to any of those internet sites, your information is governed by the privacy policies of those internet sites and we do not accept any responsibility or liability in respect of third-party sites. Please check the privacy policies published on any third-party sites which you may access thought our internet site before submitting Personal Information to them.
5. Q: Does JAMP share my Personal Information with others?
JAMP shares your Personal Information only in the following circumstances and with the following recipients:
(i) with our subsidiary undertakings and/or affiliates for the purposes of providing you with our services as described in this Notice;
(ii) with third-parties including certain service providers we have retained in connection with the services we provide;
(iii) If we have collected your Personal Information in the course of providing services to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing our services;
(iv) on a confidential basis with third-parties for the purpose of collecting your feedback on our service, to help us measure our performance and to improve and promote our services;
(v) with courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
(vi) with service providers who we engage within or outside of JAMP, domestically or abroad, (e.g. shared service centres), to Process Personal Information for any of the purposes listed above on our behalf and in accordance with our instructions only; and
(vii) if we engage in a transaction involving, for example the sale or purchase of any business or assets, a financing, or a reorganisation, we may have to disclose your Personal Information for the purposes of allowing the other party to conduct its due diligence. In such instances we will ensure that the receiving party undertakes to protect your Personal Information with appropriate security safeguards, return or destroy the information in the event the transaction does not proceed, and only use the Personal Information for the purposes of evaluating whether to proceed with the transaction.
JAMP does not sell your Personal Information
Please note: JAMP, its third-party service providers and other third parties to whom we disclose information under the Notice may perform activities outside of Canada.
Any Personal Information that is Processed in countries outside of Canada may be subject to the laws of those countries (e.g. where a third party service provider operates internationally). 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 Processing of your Personal Information outside of Canada by contacting our CPO at the contact details found in Subsection 1.1 above.
6. Q: How long does JAMP store my Personal Information?
JAMP will not retain Personal Information longer than is necessary to fulfil the purpose(s) for which it was collected including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for us 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, we invite you to contact our CPO for any inquiries pertaining specifically to you.
Upon expiry of the applicable retention period, we will securely destroy your Personal Information in compliance with applicable laws and regulations and in accordance with our document retention policy.
7. Q: How does JAMP make sure my Personal Information is accurate?
JAMP uses reasonable efforts to ensure that your Personal Information is kept as accurate, complete, and up to date as required to meet the purposes for which it is Processed. We do not routinely update your Personal Information, unless such an update is necessary. To help us maintain and ensure that your Personal Information is accurate and up to date, you must inform us, without delay, of any change in the information you provide to us.
8. Q: How does JAMP protect my Personal Information?
JAMP is committed to protecting the confidentiality, integrity, and availability of your Personal Information. We employ security safeguards that are customary in the pharmaceutical industry and appropriate to the sensitivity of the information, including physical, organizational, and technological measures. Examples of such measures include restricted access to offices, training of personnel, limiting access to information on a “need-to-know” basis, using passwords and well-defined internal policies and practices.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of data transmitted to our internet site. Any transmission you provide is at your own risk. Once we have received your information, we will apply our security practices to try to prevent unauthorized access, use and/or disclosure.
JAMP may store and Process your Personal Information at our offices in Boucherville. We use contractual and other means to provide a comparable level of protection while information is being stored, handled, and Processed using any third-party service providers.
9. Q: What are my rights with respect to my Personal Information JAMP Processes?
You have various rights with respect to our Processing of your Personal Information:
(a) Access: You have the right to request whether we hold Personal Information on you and to request a copy of such information.
(b) Accuracy: You have the right to have your Personal Information kept accurate, current, and complete for the purposes for which it is Processed. We encourage you to contact us to let us know if any Personal Information is not accurate or changes, so that we can update your Personal Information.
(c) Cessation of Dissemination: You have the right to request that we cease disseminating your Personal Information if the dissemination is contrary to the law or a court order.
You also have the right to request that we cease disseminating your Personal Information where the following conditions are met:
(i) the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
(ii) the injury is clearly greater than the public’s interest in knowing the information or of any person’s right to express themselves freely; and
(iii) the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.
(d) De-indexation: You have the right to request that we de-index any hyperlink attached to your name that provide access to information by a technological means if such access is contrary to the law or a court order.
You also have the right to request that we de-index a link providing access to information where the following conditions are met:
(i) the availability of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
(ii) the injury is clearly greater than the public’s interest in knowing the information or of any person’s right to express themselves freely; and
(iii) the de-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury.
(e) Re-indexation: You also have the right to request that we re-index a link providing access to information where the following conditions are met:
(i) a failure to do so causes you serious injury in relation to your right to have your reputation or privacy respected;
(ii) the injury caused by a failure to re-index is greater than the public’s interest in knowing the information or of any person’s right to express themselves freely; and
(iii) the re-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury.
(f) Mobility: You have the right to request that computerized Personal Information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such information. This right does not extend to information that was created or inferred from your Personal Information and we are under no obligation to communicate such information if doing so raises serious practical difficulties.
(g) Complaints: If you believe that your Personal Information protection rights have been violated, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy thought the courts.
10. Q: How do I exercise my rights?
You may enquire about your Personal Information by contacting our CPO.
JAMP will generally respond to all Personal Information requests within 30 days of the receipt of all necessary information. In circumstances where we are not able to provide access, or if additional time is required to fulfill a request, we will advise you in writing.
JAMP may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions.
11. Q: How do I withdraw my consent?
If you have provided your consent to the Processing of your Personal Information, you have the right to fully or partly withdraw your consent. To withdraw your consent please follow the opt-out links on any marketing message sent to you or contact our CPO.
Once we have received notification that you have withdrawn your consent, we will no longer Process your Personal Information for the purpose(s) to which you originally consented unless there is another legal ground for the Processing. Withdrawal of consent to receive marketing communications will not affect the Processing of Personal Information for the provision of our services.
12. Q: How are my concerns resolved?
Any report, concern, complaint or incident of which we become aware that involves conduct that may contravene this 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.
You may report your concerns about the Processing of your Personal Information directly to our CPO. The CPO will engage the appropriate levels of management to assist with resolution of the issue.
While we are committed to resolving all Personal Information matters internally, nothing in the Notice precludes you from contacting the appropriate federal or provincial privacy commissioner.
JAMP will not retaliate against a person who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their Personal Information.
13. Q: What are the roles and responsibilities of JAMP employees in protecting my Personal Information
JAMP is responsible for communicating this Notice and ensuring that employees fully comply with all relevant aspects of the Notice and the accompanying guidelines.
Our business or infrastructure units that Process Personal Information are responsible for ensuring that they do so in compliance with the Notice.
Our CPO is responsible for:
(a) developing JAMP’s Personal Information Protection strategy;
(b) developing and maintaining this Notice, accompanying guidelines and any other policy or procedure related to Personal Information in compliance with applicable law; and
(c) serving as the official liaison with the federal and provincial commissioners.
14. Q: May this Notice be updated
JAMP reserves the right to interpret the Notice at its sole discretion and to make changes as it deems appropriate from time to time without the requirement of advanced notice.
Personal Information protection legislation continues to evolve and, as a result, this Notice may be amended by us from time to time at our full discretion without any prior notice or liability to you or any other persons. The Processing of your Personal Information by us will be governed by the version of this Notice in effect at that time.