WYETH CANADA INTERNET PRIVACY POLICY
LAST MODIFIEDThis Policy was last modified on August 3rd 2006.
INTRODUCTION
a) The Application of this Privacy PolicyWyeth, with its pharmaceutical, consumer health care, and animal health care divisions, and its affiliated companies around the world, is a leader in the research, development, manufacturing and marketing of a broad range of health care products.
This Internet privacy policy ("Policy") applies to web sites owned and operated by Wyeth Canada (sometimes referred to herein as "Wyeth", "us", "we" and "our") and hereinafter referred to as the "Wyeth Site" or "Wyeth Sites". See Section 5 below with respect to "Co-Branded Web Sites", which Wyeth may jointly own with a third party.
Any personal information you disclose to Wyeth's U.S. parent, or any of its affiliates or joint venture partners, will be governed by their own privacy policies.
(b) Your ConsentBy using a Wyeth Site, you acknowledge that you have read and understood this Policy and consent to our collection, use and disclosure of your personal information as set forth herein.
(c) Information Posted on Wyeth SitesPlease note the information presented on Wyeth Sites is not intended to be a substitute for medical advice or treatment for specific medical conditions. Use of a Wyeth Site is subject to its Terms & Conditions.
(d) Personal Information"Personal information" is information that can identify you as an individual and includes information such as your name, e-mail and mailing address, date of birth and the answers you provide to health-related questionnaires. Information may cease to be "personal information" when it is stripped of all identifiers or aggregated with personal information collected from other individuals.
(e) Changes to the PolicyThis Policy may be changed periodically. By using Wyeth Sites, you acknowledge our right to change this Policy. Any changes will be posted on the Privacy Policy page of Wyeth Sites. We recommend that you visit the Privacy Policy page whenever you visit a Wyeth Site to ensure you are aware of the current Policy.
(f) Children's PrivacyWyeth Sites are not intended for, or targeted towards, children under the age of 13. We do not knowingly collect personal information online from visitors in this age group.
OUR COMMITMENTWyeth respects, and is committed to protecting, your privacy. The goal of the Policy is to explain how we protect your privacy. The Policy is based on the Canadian Standards Association's ten principles for protecting personal information, the Personal Information Protection and Electronic Documents Act ("PIPEDA") and other applicable privacy legislation.
1. ACCOUNTABILITYThe Privacy Officer is responsible for Wyeth's compliance with PIPEDA, other applicable privacy laws, and the Policy. Wyeth has procedures in place to implement the Policy, including procedures for receiving and responding to complaints, and programs to educate our staff about their responsibilities under PIPEDA, other applicable privacy laws, and the Policy. Wyeth uses contractual or other means to require agents and contractors (discussed below) to handle your personal information only as directed by Wyeth.
2. IDENTIFYING PURPOSESWyeth collects personal information for a variety of purposes. Generally, the purpose for collecting your personal information will be explained to you, in clear language, at the time of collection. Where the purpose for collecting personal information is obvious, your consent is implied.
From time to time, we may ask for personal information when you complete a survey or enter a contest. We use this information to learn more about Wyeth Site users and our products, and to administer the survey or contest respectively. In other circumstances, we may collect your e-mail address to deliver web-enabled services to you, such as e-mail newsletters. When presenting you with such opportunities on Wyeth Sites, we will generally describe the purpose for collecting, and the intended uses of, such information.
We conduct research on user demographics, interests, and behaviours based upon information provided to us during use of Wyeth Sites. We may combine your information with information collected from other individuals to produce anonymous, aggregated, and statistical data, which does not include personal information. We use this information, such as the percentage of male or female visitors, or the percentage of visitors within certain age brackets, to improve the content of Wyeth Sites. We may share this anonymous, aggregated, and statistical data with partners or other third parties.
3. CONSENTYour knowledge and consent are required for our collection, use or disclosure of your personal information. When you visit a Wyeth Site, we may ask you for personal information. It is your choice whether or not you submit personal information to us. Generally, when you voluntarily provide us with your personal information, we will assume you consent to our collection, use and disclosure of that information for the purposes identified at the time of collection.
Sometimes we will seek your express consent. For example, on a registration page for a Wyeth Site, we may ask if you want to register for e-mail distribution or other services using an "opt-in" mechanism. You will not receive communications or services from us unless you click the box expressing your express consent. For certain communications and services, we verify your express consent prior to commencing the requested service.
For a summary of our policy concerning linked web sites and information that we collect through technological means, such as "cookies" and "IP Addresses", please refer to Web Site Technology.
(a) Withdrawal of ConsentIf, at any time, you decide you do not wish to receive communications or other services from us, you can let us know by: (i) changing your choice on the relevant Wyeth Site, where available; (ii) using the unsubscribe feature, in the case of e-mail distributions; or (iii) contacting us using the Contact Information below.
(b) No Consent RequiredUnder PIPEDA, and other applicable privacy legislation, there are limited circumstances where Wyeth may collect, use or disclose personal information without your knowledge and consent. For example, personal information may be collected: where regulations specify that the information is "publicly available" (i.e., telephone directories); for the purpose of responding to an emergency that threatens the life, health or security of an individual; or to comply with a subpoena, warrant or other court order.
4. LIMITING COLLECTIONWyeth limits the collection of personal information to that which is necessary to fulfill identified purposes.
5. LIMITING USE, DISCLOSURE, RETENTION UseWyeth does not use or disclose your personal information for purposes other than those identified at the time of collection. If we want to use your personal information for purposes not identified at that time, we will obtain your consent, unless use of your personal information for the new purpose is required by law.
Disclosure(i) Marketing. We do not sell, trade, or rent your personal information to others for marketing purposes.
(ii) Agents and Contractors. We may share your personal information with third-party agents and contractors hired to perform certain services on our behalf, such as fulfillment services, technical support, delivery services, and financial institutions.
(iii) Cross-Border Transfer of Personal Information for Processing. For processing purposes, Wyeth may transfer your personal information to agents and contractors located outside Canada in jurisdictions that may not have equivalent laws and rules regarding privacy and data protection. As with domestic agents and contractors, Wyeth uses contractual or other means to require these agents and contractors to handle your personal information only as directed by Wyeth. Wyeth will notify you prior to any such transfer for processing purposes.
(iv) Co-Branded Web Sites. Wyeth may partner with other companies to provide you with a service or information about a product through a web site. On the homepage of a co-branded web site you will generally see Wyeth's name and the name of its co-branded partner(s). Any information that you provide on a co-branded web site will generally be collected and used by both Wyeth and its co-branded partner for the purposes identified at the time of collection. Accordingly, we encourage you to read the privacy policy of our co-branded partner, as it may differ in some respects from our own. Reading our partner's policy will help you decide whether to provide your information to a co-branded web site.
(v) Disclosure of Personal Information to Wyeth's US Parent, Affiliates and Joint Venture Partners. As a global company, there may be circumstances where Wyeth discloses your personal information to our US parent, affiliates or joint venture partners, some of whom may be located in jurisdictions outside Canada. Prior to such disclosure, we will obtain your consent in accordance with this Policy.
(vi) Sale, Assignment of Business. In the event Wyeth goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its products or assets, your personal information will likely be transferred. We will make every effort to notify you via e-mail, letter or public posting of any such change in the control of your personal information. At the time of notification, you will be given a clear choice to allow the use of your personal information for secondary purposes, such as product information, research, promotions, discounts and other business communications.
(vii) Permitted or Required by Law. Applicable privacy laws in Canada permit or require the disclosure of personal information without consent in limited circumstances. Where permitted or required by applicable laws, Wyeth may disclose your personal information.
RetentionWe retain your personal information only as long as necessary to fulfill identified purposes, unless a longer retention is permitted or required by law.
6. ACCURACYWyeth takes reasonable steps to ensure your personal information is accurate, complete, and up-to-date. However, in certain circumstances, we rely upon you to advise us if your personal information changes. If you notify us that your personal information is inaccurate or incomplete, we will take steps to correct, delete, or add to it, as appropriate.
7. SAFEGUARDSWe use physical, administrative and technical safeguards, appropriate to the sensitivity of the information, to protect your personal information against loss, theft, misuse, unauthorized access, disclosure, copying and alteration. Safeguards include Secure Sockets Layer (SSL) technology, which protects the transmission of personal information over the Internet by encrypting it prior to transmitting it from your computer to our servers.
Although we attempt to safeguard personal information, we cannot guarantee it is completely secure from individuals who might attempt to deliberately evade security measures or intercept transmissions over the Internet.
8. OPENNESSThis Policy is intended to provide information about how we collect, use or disclose your personal information. If you have any questions not answered by this Policy, or any comments on this Policy, please contact us using the Contact Information below.
9. INDIVIDUAL ACCESSYou have a right to request access to, and to challenge the accuracy and completeness of, your personal information. You also have a right to receive a general accounting of how that information has been used and disclosed, subject to certain circumstances prescribed by law. For example, if the requested information is subject to solicitor-client or litigation privilege, or would reveal personal information about another individual, your request for access may be limited or denied. If your request for access is denied, Wyeth will notify you in writing of the reason for the denial. With some Wyeth Sites, you may log in to your account profile or preferences to view and/or modify the information, as appropriate.
To request access to, or to amend, your personal information, please contact us in writing using the Contact Information below. We may need to verify your identity before responding to your request. Wyeth will generally respond within thirty (30) days of receipt of your written request.
10. CHALLENGING COMPLIANCEWyeth has procedures in place to receive and respond to inquiries about its policies and practices relating to its handling of personal information. Inquiries should be directed to Wyeth’s Privacy Officer using the Contact Information below.
Wyeth will investigate all complaints and will respond within 30 days of receipt of a written inquiry. If the complaint is justified, Wyeth will take appropriate measures to resolve it, including, if necessary, amending this Policy and its procedures.
Contact InformationIf you have any questions, comments or complaints about this Policy or our handling of your personal information, or if you wish to withdraw your consent to our use of your personal information or to request access to or update any information we have on file, please contact our Privacy Officer using the contact information below:
| By email: | privacyofficer@wyeth.com |
| By telephone: | 905-470-4311 |
| By mail: |
Wyeth Pharmaceuticals 50 Minthorn Boulevard Markham, Ontario L3T 7Y2 Attention: Privacy Officer |
Please note the name of the Wyeth Site, or other online resource, which is the subject of your inquiry, as well as the nature of the information about which you are inquiring. We will use reasonable efforts to respond promptly. Except where required by law, Wyeth cannot ensure a response to questions or comments regarding topics unrelated to this Policy or Wyeth's privacy practices.
If any inquiry or complaint is not resolved to your complete satisfaction, you may contact:
Office of the Federal Privacy Commissioner
112 Kent Street
Ottawa, Ontario
K1A 1H3
Telephone: 1-613-995-8210
Toll Free: 1-800-282-1376
E-mail: http://www.privcom.gc.ca
WEB SITE TECHNOLOGY
CookiesOur servers deposit small text files called "cookies" on your hard drive when you visit Wyeth Sites. Cookies are used to store information. Wyeth Sites use two types of cookies: "session cookies" and "persistent cookies".
Session cookies are deposited for the length of your stay on the web site, and are deleted when you shut down your browser or turn off your computer. We use these cookies to collect aggregate statistical information about how visitors use our web sites, such as the pages they visit and the length of their visit. We use this information to improve the design and content of Wyeth Sites. We may share this information with our US parent, affiliates, joint venture partners and other third parties. In addition, we often use these cookies for security purposes to ensure only registered users are permitted access to certain Wyeth Sites.
Persistent cookies remain on your computer’s hard drive until you delete them and can be re-read when you return to the web site that deposited them on your hard drive. If you register for a Wyeth Site (or a section of a Wyeth Site), we will deposit a persistent cookie on your hard drive to remember information you gave us when you registered (i.e., user name, password, language preference) so you do not have to re-enter it with each visit and to provide you with access to areas of Wyeth Sites limited to registered users. Generally, we will ask you whether a Wyeth Site may place a persistent cookie on your hard drive.
We are only able to access and read those cookies that we place, not those placed by third parties.
Most browsers are defaulted to accept and maintain cookies. To learn more about cookies, and how to specify your cookie preferences, please search for "cookie" in the "Help" portion of your browser. You can configure your browser to accept all cookies, reject all cookies, or notify you whenever a cookie is set. If you simply want to browse a Wyeth Site, you do not have to accept cookies. However, if you would like to register and log in to special areas of a Wyeth Site, you will need to re-set your browser to accept cookies, otherwise, navigation of those areas may be impaired.
Pixel TagsTo measure the effectiveness of, and/or traffic on, Wyeth Sites, we may use "pixel tags" (also called clear GIFs, web beacons, and web bugs) in conjunction with cookies. A pixel tag is a type of web page graphic, usually only 1x1 pixel in size, used to track the number of Wyeth Site users and their navigation through particular pages of our sites.
We sometimes include pixel tags in our HTML-formatted e-mail messages to determine which messages were opened and whether they were acted upon. You may render some pixel tags unusable by rejecting their associated cookies.
We do not use pixel tag technology to collect personal information.
IP AddressesAn Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP) whenever you connect to the Internet. Like other web sites, Wyeth Sites may collect IP addresses to analyze aggregate information about the number of visitors to our sites and site usage. We do not link your computer's IP address with personal information you provide. Where permitted by law, Wyeth reserves the right to use IP addresses to identify individuals who threaten the security of a Wyeth Site, a service, or a Wyeth Site user.
ClickstreamA "clickstream" reflects the specific web pages visited by an individual user and, importantly, the manner or traffic pattern by which a user moves from one web page to another. We track such information only within Wyeth Sites.
Clickstream data that we collect does not contain or reveal any personal information about the user, and we do not match that data with the personal information you provide.
LEAVING WYETH SITESAs a resource to Wyeth Site users, we may provide links to third-party web sites. We try to choose sites we believe are useful and meet our high standards. However, we do not guarantee the standards of every linked web site, nor are we responsible for the content of non-Wyeth Sites. Wyeth does not endorse linked third-party web sites. These links are provided for convenience and/or informational purposes only.
Please be aware that owners of third-party web sites, or advertisers on such sites, may collect personal information from you. This Policy does not cover the privacy practices of third-party web sites. We suggest that, when linking to a third-party web site, you first read the site’s privacy policy before navigating that site.