BELLATRX PRIVACY POLICY
Our Commitment to the Protection of Personal Information
BellatRx Inc. (hereinafter collectively referred to as “BelltaRx“, “we” or “us”) are committed to protecting the privacy, confidentiality, accuracy, and security of the personal information they hold.
It is with this in mind that we have adopted this privacy policy (hereinafter the “Policy“), which sets out how we collect, hold, use or communicate to third parties the personal information of our clients and other individuals (“you”), other than BellatRx’s employees and contracted staff, which is dealt with separately.
We are committed to treating any personal information we collect with care, within the limits of this Policy and applicable law.
Types of Personal Information
The Policy applies to personal information regardless of the type of medium or the form in which it is accessible: written, graphic, sound, visual, taped, filmed, computerized, or others.
By definition, personal information is any information concerning a natural person that directly or indirectly allows that person to be identified. By way of illustration, personal information could consist of, but is not limited to:
- first and last name;
- date and place of birth;
- telephone and fax numbers, home address and e-mail address;
- information appearing on government-issued identification (driver’s license, passport, or similar documents);
- tax residence and tax identification number information;
- financial, credit, billing, and account information;
- details about the use of our website, obtained by means of cookies or similar tools;
- recruitment-related information such as curriculum vitae, information about your professional or academic background, or any other information relevant to potential recruitment; and
- any other personal information provided.
The Purposes for which we Collect Personal Information
We collect, use, or disclose personal information for the following purposes:
- to provide our products and services, including our website www.bellatrx.com (hereinafter the “Website”);
- to develop and manage our business, activities and operations;
- to comply with our legal, regulatory and risk management;
- to evaluate a job candidate’s application and to determine whether to offer a job candidate a position at BellatRx.
- to prevent fraud or to conduct background checks as required by applicable law;
- as provided in section 5 below;
- any purpose permitted or required by applicable laws;
- any other purpose to which you have consented.
Means by which we Collect Personal Information
We collect personal information directly from the person concerned in the course of providing our products and services, including when you use our Website. We may also collect information from a number of independent private and public sources, such as our service providers, social networks, recruitment agencies and other business partners.
We may additionally collect information passively using cookies, which are small text files or strings that a website can send to your device to identify your web browser and the activities of your computer on the Website and other websites. This mainly consists of IP address, type of operating system, pages visited, requests made, dates and times of connections. We may use cookies, for example, to personalize your experience on the Website or to allow us to statistically track how you use the Website, all in order to help us improve it and provide you with a better browsing experience.
The use of cookies does not allow us or our analysis service providers to identify you specifically. Furthermore, it does not give us access to your device or any other information about you, other than the data you choose to share with us. You can accept, reject or customize your cookie preferences through the cookie banner displayed when you enter our Website. Please note that if you choose to reject cookies or customize your preferences, you may not be able to access or fully experience the interactive features of the Website.
Outsourcing of Personal Information and Transfer Outside of Quebec
We may be required to disclose the personal information we have collected to third parties in the following circumstances :
- to third-party in connection with our services, products and business (e.g., data storage and processing, cloud computing, website hosting, security or office services);
- to comply with an applicable statute, regulation, rule of law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other legal process;
- to allow us to enforce available recourses or limit the damages we may suffer;
- to protect the safety and/or security of our users, the Website, our services, or the general public (including you);
- in the event of a commercial transaction, namely the sale, transfer or assignment, in whole or in part, of BellatRx or our assets; and
- any other circumstances to which you have consented.
Additionally, it is possible that some of your personal information may be transferred to places other than Quebec. Indeed, we may call upon use service providers located outside of Quebec to carry out specific mandates in the normal course of business. Furthermore, your personal data is stored in data centers located in Canada and the U.S.A.
To protect your information in all such cases, we use contractual and other means to provide a comparable level of protection to that used by BellatRx (as outlined in Section 8).
Rest assured that we will never, by any means, sell or exchange your personal information for payment.
Your Consent under this Policy
We will not collect, hold, use or disclose personal information without your consent unless it is authorized or required to do so by applicable law.
By submitting your personal information or using our products and services (including accessing our Website), you consent to the collection, use and disclosure of your personal information to the extent described in this Policy and as required or permitted by applicable law.
If you provide personal Information concerning another individual (including adverse parties and other individuals involved in legal proceedings) to us, you represent that, prior to submitting such information, you have obtained the necessary consent or authority to permit us to collect, use and disclose such personal information for the purposes set out in this Policy, or the collection, use and disclosure is permitted by applicable law.
You may vary or withdraw your consent to the use and disclosure of your personal information, or opt-out of certain uses and disclosures, subject to legal and contractual restrictions. Please note that the withdrawal of your consent may prevent us from providing or continuing to provide you with our products or services.
If you require any assistance in understanding the scope of the consent being sought or to vary or withdraw your consent, please contact our Privacy Officer (see Section 10) for more information.
Your Rights
You have, inter alia, the following rights regarding your personal information:
- to request an exported or physical copy of the documents containing your personal information, subject to the exceptions provided by applicable law;
- to have the personal information we have about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
- to request the deletion of your personal information when : i) the retention of the information is no longer justified for the purpose for which it was collected (and subsequent related and compatible purposes) or the applicable law; or iii) the information was not collected in a lawful manner; and
- to withdraw or change your consent to our processing of your personal information, subject to applicable legal and contractual restrictions. In some instances, withdrawing your consent may result in BellatRx no longer being able to provide you with our services or products.
How we Safeguard Personal Information
In order to protect the personal information that is in our possession, we employ administrative, physical, and technological safeguards which are appropriate to the sensitivity of the personal information provided. These safeguards also prevent the accidental or unlawful destruction, loss, unauthorized alteration or disclosure, access, or misuse of the personal information in our possession. We follow generally accepted industry standards to protect the information that is provided during its submission and once it has been received. Once communicated, the personal information is securely kept in a file, either physically at BellatRx office, electronically within our document management system or third-party technologies used by BellatRx, or both. Only those personnel who reasonably require the personal information to perform their duties are granted access to the information and they are bound by a duty of confidentiality.
It is important to note that despite our best efforts to protect your personal information, there is a risk involved in the communication, exchange and safeguarding of information, as no method of electronic transmission or storage is completely secure. BellatRx assumes no liability for any destruction, loss, unauthorized access or disclosure, or alteration of personal information, or any damages suffered in consequence thereto. That said, rest assured, if a confidentiality incident occurs at BellatRx, we have put in place a policy for handling confidentiality incidents as well as an incident response plan in accordance with applicable law.
Retention and Destruction of Personal Information
Personal Information we collect is retained for varying lengths of time according to the type of information in question and the purposes for which it is collected and used. We delete or anonymize Personal Information when there is no longer a need to use it for the purposes for which it was collected, or subsequent purposes related to and compatible with the original purposes of collection. We may retain archival copies of Personal data for legal or security reasons.
If you wish to learn more about how long we keep your Personal Information, we invite you to contact our Privacy Officer.
How to Contact Us
In order to obtain more information on the Policy or the use of your personal information, to exercise your rights or to file a complaint, please contact our Privacy Officer at the following coordinates:
BellatRx Inc.
Attn: Privacy Officer
20655 Boul. Industriel
Saint-Anne-de-Bellevue, QC
H9X 4B2, Canada
Changes to this Policy
We may change the Policy, at any time and at our sole discretion, by posting the amended terms on the Website. Changes will be effective immediately upon posting on the Website. If you do not agree with the updated terms of the Policy, you should stop using our services or products and contact our Privacy Officer. Failing to do so indicates your acceptance of the updated terms of the Policy. It is your responsibility to regularly review this Policy.
