Feldan Therapeutics (« Feldan » or « we ») respects your privacy and is committed to protecting your personal information. This privacy policy (the « Policy ») describes how we treat your personal information when you visit or use our website at www.feldan.com (the « Website »), regardless of where you visit or use our website from, your privacy rights and how the law protects you. This Policy does not apply to the use or collection by Feldan of personal information provided to Feldan by third parties as a result of your participation in clinical studies. If you are concerned by this type of collection, please refer to Feldan's clinical study consent form.
When you submit personal information to Feldan or consent to its collection by Feldan, you agree that Feldan may use and disclose such personal information in accordance with this Policy and as permitted by law. Subject to legal and contractual requirements that may apply, you may refuse or withdraw your consent to our use or disclosure of your personal information at any time by contacting our Privacy Officer identified in Section 10 of this Policy.
If you do not agree with this Policy, please do not use the Website. By accessing or using the Website, you agree to be bound by the terms of this Policy.
1. What Personal Information do we Collect About you?
Personal information is any information that directly or indirectly identifies an individual.
Through the process of navigation on the Website, we may collect, use, store and disclose the following categories of personal information:
• Information on identity, such as first name, surname, given name and title.
• Personal contact information, such as e-mail address, postal address, zip code and telephone numbers.
• Technical information, such as Internet Protocol (IP) addresses and information on the region or city where your connection is made, cookies and other technologies on the devices you use to access this Website.
• Information about Internet activity, such as browsing history, search history and interactions with our website and online advertisements.
• Career profile information, such as your resume and other information you choose to share via the website as part of the Feldan hiring process.
If you provide Feldan with the personal information of another individual, you acknowledge that you have obtained all necessary consents from that individual to authorize us to collect, use and disclose that personal information for the purposes and in the manner set out in the present Policy.
2. How do we Collect your Personal Information?
We use a variety of methods to collect your personal information, including the following:
2.1. Direct Interactions
When you communicate directly with us, you may provide us with your personal information, such as the information you provide to us at the following times:
• using the form on our website to contact us;
• by using the form on our career page;
• by voluntarily communicating your personal information during a communication with us by any other means for any other purpose.
2.2. Automated Technologies or Interactions
When you interact with our website, we may automatically collect personal technical and Internet activity information about your computer equipment. We also use the Google Analytics platform to analyze the use of our website, for statistical purposes and continuous improvement of the user experience.
The following information may be collected by Google Analytics using cookies:
• your IP address;
• the day and time you visit our website;
• browser language;
• country, region or municipality (determined from IP address);
• browser type and version;
• type of operating system used (IOS, Android, Windows);
• the type of visitor you are (new or returning);
• the number of sessions and pages visited per session;
• the type and model of device used (phone, tablet, computer);
• the domain of the previous site visited;
• the address of pages visited on the website;
• your activities (e.g. clicking, scrolling) on the website;
• the point of origin of your visit (banner, e-mail, social network, print publication, advertiser's website);
• the type of customer you belong to (e.g.: individual, group, organization);
• your customer category (e.g. residential, business);
• the screen resolution of the device you're using (in the case of a mobile device).
You may prevent Google from collecting data about your use of our website by downloading the Google Analytics Opt-out Browser Add-on.
3. Why do we Collect and Use your Personal Information?
We may use and disclose your personal information for the purposes for which it was collected, as set out in this Policy, and for other purposes permitted by law, or as otherwise described at the time of collection.
We may use and disclose your personal information for the following purposes, particularly for the following purposes:
Purpose
|
Type of Personal Information
|
Reply to your communications.
|
- Information on identity
- Personal contact information
|
Provide access to our online recruitment service and process your application for a position offered by Feldan.
|
- Information on identity
- Personal contact information
- Career profile information
|
| Research and development, in particular to analyze and improve our services. |
- Technical information
- Information about Internet activity
|
4. Career Page
Feldan allows you to apply directly by sending your application for a position offered by Feldan via the form available on the website or, alternatively, by sending an unsolicited application. To update or delete documents you have uploaded, or to modify or delete your profile, you may contact our Privacy Officer.
5. Retention of Personal Information
Feldan retains your personal information only as long as necessary for the purposes for which it was collected or as long as necessary to comply with any applicable legal obligations.
By using Google Analytics services, Feldan may export reports containing audience statistics or browsing behavior. These documents are anonymized and contain no reference to IP address (it is not possible to link the data to a specific individual).
When the personal information collected is no longer required by Feldan or when otherwise required by law, the necessary procedures to destroy, delete, erase or convert it to an anonymous form are applied.
In certain circumstances, we will anonymize your personal information (so that it can no longer be associated with you) for study, research or statistical purposes, and only for serious and legitimate purposes, in which case we may use it indefinitely without further notice.
In addition, your personal information may be stored in Canada or abroad. We ensure that the necessary security measures and contractual agreements are in place to protect your personal information.
6. Protection of your Personal Information
We work with reputable technology service providers to protect your personal information through measures such as:
• Inventory and control of our information assets;
• Inventory and control of our software assets;
• Implement processes and technical controls to identify, classify, manage, store and dispose of our data securely;
• Secure configuration of our information and software assets;
• Account management ;
• Access control management;
• Ongoing vulnerability management.
7. Your Rights
Subject to certain exceptions provided for in applicable laws, you have the following rights with respect to the personal information we collect about you:
7.1. Your Right of Access
You have the right to access your personal information held by us and to receive a general account of our use of that personal information. Within a reasonable time of receiving your written request, we will provide you with a copy of your personal information. Please note, however, that in certain circumstances, we may refuse to make available to you all the personal information requested, for example, where that personal information also relates to another individual. In such circumstances, we will inform you of the reasons for our refusal within the time limits set by applicable laws.
7.2. Your Right to Rectification
If the personal information we hold about you is inaccurate or incomplete, you have the right to ask us to correct it. If you have the right to rectification and we have shared your personal information with third parties, we will inform them of the rectification where possible and where this does not require a disproportionate effort on our part. Upon request, where possible and legal, we will also tell you to whom we have shared your personal information, so that you can contact them directly to make the rectification. We reserve the right to refuse your requests for rectification on reasonable grounds within the time limits provided by applicable laws.
7.3. Your Right to Request Information About Data Processing
You may contact us for information about our personal information handling activities, including what personal information has been collected about you and how it is handled by Feldan. You may ask us to specify the categories of persons who have access to your personal information at Feldan and the applicable retention period for that information.
7.4. Your Right to Withdraw your Consent
If we rely on your consent (or express consent) as the legal basis for processing your personal information, you have the right to withdraw that consent at any time by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, this may result in limitations on the functionality you can access on the Web site, and on our ability to respond to your online communications or applications. We will advise you if this is the case at the time you withdraw your consent.
7.5. Your Right to Make a Complaint to a Privacy Regulator.
You have the right to file a complaint at any time with the appropriate regulatory body. In Canada, you may contact the Office of the Privacy Commissioner of Canada or the Privacy Commissioner of your province of residence, including the “Commission d'accès à l'information du Québec”.
8. Protecting your Personal Information
Feldan strives to protect the confidentiality of your personal information. Nevertheless, communications on the Internet are never perfectly private or secure. Therefore, despite the efforts made by Feldan, we cannot guarantee the absolute security of the personal information you transmit to us.
This does not limit the duty of Feldan and others to protect the confidentiality of your personal information.
In the event of a confidentiality incident involving your personal information and presenting a risk of serious harm, Feldan, in accordance with obligations under applicable laws, will notify you of the incident within a reasonable time.
9. Changes to the Policy
We reserve the right to change this Policy from time to time if we deem it necessary or required by law. We will notify you of such changes by posting the latest version of this Policy on our website as soon as possible after its update. We will treat your personal information in accordance with the privacy policy in effect at the time when the information is collected, or in the manner agreed with you.
Of all translated versions of this Policy, the French version shall prevail in the event of differences.
10. Contact Us
If you have any questions, concerns or inquiries regarding the collection, use or disclosure of your personal information, please contact our Privacy Officer at privacy@feldan.com.
