Last updated: 15 June 2018
Concordia International Corp. and its group entities (“Concordia” or “we”) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the end of this Privacy Notice.
What does Concordia do?
Concordia is a diverse, international specialty pharmaceutical company, headquartered in Ontario, Canada. Our products are sold in more than 90 countries around the world.
What personal information does Concordia collect and why?
The personal information that we may collect about you broadly falls into the following categories:
- Information that you provide voluntarily
Certain parts of our website may ask you to provide personal information voluntarily. For example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. If you contact us by telephone or in writing, we may keep a copy of that correspondence or communication. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
- Information that we collect automatically
When you visit our website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (the “EEA”), this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
- Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources (including recruiters), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
The types of information we collect from third parties include details about your professional and academic history and we use the information we receive from these third parties to e.g. maintain and improve the accuracy of the records we hold about you.
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws. Concordia does not sell, rent or lease its customer lists to third parties.
Who does Concordia share my personal information with?
We may disclose your personal information to the following categories of recipients:
- to our group companies, third party service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A list of our current group companies and a list of our current service providers and partners is available on request.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, restructuring, financing, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
Legal basis for processing personal information
Our legal basis for processing the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally process personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (e.g. for tax purposes).
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
Cookies and similar tracking technology
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner (in this case, Concordia) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.
We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our websites. Third parties may serve cookies through our websites for advertising, analytics and other purposes. This is described in more detail below.
The specific types of first and third-party cookies served through our websites and the purposes they perform are described in the table below:
|Types of cookie||Who serves these cookies||How to refuse/block|
|Essential website cookies: These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas.||www.concordiarxinternational.com||Because these cookies are strictly necessary to deliver the websites to you, you cannot refuse them.
You can block or delete them by changing your browser settings however, as described below under the heading “How can I control cookies?”
|Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective are marketing campaigns are, or to help us customise our websites for you.
|www.concordiarxinternational.com||To refuse these cookies, please follow the instructions below under the heading “How can I control cookies?”
Alternatively, please click on the relevant opt-out link below:
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our websites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our websites to another, to deliver or communicate with cookies, to understand whether you have come to our websites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
Does your website use third party links?
In an attempt to provide you with increased value, we may include third-party links on our websites. These linked sites have separate and independent privacy policies. Concordia has no responsibility or liability for the content and activities of these third-party linked sites. Nonetheless, Concordia seeks to protect the integrity of our website and welcome any feedback about these linked sites (including if a specific link does not work).
Do you use Flash cookies or Local Shared Objects?
Our websites may also use so-called “Flash Cookies” (also known as Local Shared Objects or “LSOs”) to, among other things, collect and store information about your use of our services, fraud prevention and for other site operations.
If you do not want Flash Cookies stored on your computer, you can adjust the settings of your
Flash player to block Flash Cookies storage using the tools contained in the Website Storage Settings Panel.
You can also control Flash Cookies by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time).
Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.
Do you serve targeted advertising?
Third parties may serve cookies on your computer or mobile device to serve advertising through our websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.
How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided in the cookie table above.
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/
Commitment to Children’s Privacy
To protect children’s personal information and to meet the standards of the Children’s Online Privacy Protection Act (“COPPA”) in the US, we do not knowingly collect any personal information from children under the age of 13. This website is a general audience website and is not geared toward children.
In addition, we do not collect any personal information from anyone who we know to be under the age of 18. If you are under the age of 18, you should use this website only with the involvement of a parent or guardian and should not submit any personal information to us.
Other country specific rights may apply to individuals in other jurisdictions. For more information please contact us using the contact details provided under the “How to contact us” heading below.
How does Concordia keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of that information during its transmission or its storage in our systems. We restrict and limit access to personal information only to those of our employees or authorized service providers who need it to carry out their business functions for Concordia, and our employees understand their requirement to safeguard personal information and prevent its unauthorized access, disclosure, or use. We also require each of our authorized service providers who need such information to safeguard against such unauthorized access, disclosure or use. If one of the websites requires a login name and password, you are responsible for the security of your login and passwords. Make sure you keep them in a safe place and do not share them with others. Always remember to logout after your session ends to ensure that other people cannot access your account information.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our website servers are located in North America, United Kingdom, Ireland, Sweden and Australia, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice and the applicable privacy laws.
Data transfers between Concordia group companies, including between group companies in different countries, are covered by inter-company agreements which require all group companies to protect personal information that they process. Where data is transferred from EEA to a non-EEA country, these include implementing the European Commission’s Standard Contractual Clauses. Our Standard Contractual Clauses can be provided on request.
We implemented similar safeguards with our third-party service providers and partners and further details can be provided upon request.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it.
Your data protection rights
If you are visiting the website from the EEA, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us at email@example.com or by using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- If you believe your data has been collected inappropriately, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Your California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities). To obtain this information from Concordia, please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. Concordia will provide the requested information to you at your e-mail address in response. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Other country specific rights may apply to individuals outside of the EEA. For more information please contact us using the contact details provided under the “How to contact us” heading below.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws, otherwise your continued use of any website after such change constitutes your agreement to be bound by the revised Privacy Notice.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
Concordia International Corp., 277 Lakeshore Rd E, Suite 302, Oakville, Ontario L6J 1H9, and after July 1, 2018 at 5770 Hurontario Street, Suite 310, Mississauga, Ontario, L5R 3GS.
Concordia International Rx (UK) Limited, Capital House, 85 King William Street, London, EC4N 7BL
The data controller of your personal information is the Concordia entity in your country, details of which can be provided to you upon request.