Privacy Policy for ANUSOL.ca

Johnson & Johnson Inc. ("JJI","we","us" or "our") recognizes our responsibility to protect personal information in our custody or control. "Personal information" is information about an identifiable individual, such as your name, address, email address, phone number, health information, and comments or inquires you have made about our products or services when such comments or inquiries are linked to you.

This Privacy Policy applies to individuals who deal with us in Canada including consumers, patients, healthcare professionals and others within the healthcare or pharmaceutical industries ("you" or "your"), and explains how we collect, use, disclose and protect your personal information. This Privacy Policy does not apply to information about our employees or to information that is not personal information. JJI does not control the content or the privacy policies of third party on-line resources to which our web sites may provide links and this Privacy Policy does not, therefore, apply to any such resources.

By providing information to us, you agree with the terms of this Privacy Policy. Whenever you submit information to us, for example via one of our web sites, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy. Please be sure to read this entire Privacy Policy before submitting information to us.

Personal Information Collection

JJI and its agents and representatives collect personal information in a number of circumstances, including when you provide it to us voluntarily or in other circumstances with your consent or as permitted or required by law. For example, we may collect your personal information when you:

  • request information or products;
  • inquire or provide comments about our products and services;
  • participate in advisory boards;
  • participate in clinical trials;
  • participate in contests or other promotions;
  • fill out questionnaires or surveys;
  • purchase a product directly from us;
  • interact with our web sites;
  • participate in social media forums, or post information on bulletins, sponsored blogs or on our web sites;
  • submit your resume or other personal information in connection with employment possibilities with us; or
  • otherwise provide your personal information to us, including by telephone, mail, email, facsimile, through any of our web sites, by chat application or by SMS/text messaging or other electronic means.

The information we may collect includes:

  1. personal and business contact information, such as name, title, address, telephone number and email address;
  2. name, address, age, recorded information (such as a video), photographic images, in connection with promotions such as contests;
  3. consumer preferences and consumer comments about our products and services;
  4. names and other contact details of consumers who use our products and their physicians and, in certain circumstances, sensitive health information, and patient medical history, for example, where we have received a report of an adverse event, or where we are assisting in or co-ordinating product recalls;
  5. information collected in connection with inquiries or comments made by individuals who contact our consumer care centre;
  6. names and other contact details of physicians participating in advisory boards and the opinions or comments expressed by those physicians during advisory board meetings;
  7. names and other contact details of physicians involved in running clinical trials, together with their professional information such as curriculum vitae and other information that is required to be reported to Health Canada and other regulatory bodies;
  8. information such as name, age, and gender of patients participating in clinical trials together with the clinical data collected in the course of the clinical trials. JJI generally receives patients' clinical data that has been recorded using identifiers other than the patients' full name, such as the patients' initials. More comprehensive patient data, including full names, may be reviewed by our clinical site managers when they attend at the trial site for compliance monitoring;
  9. information from individuals visiting our premises such as their name and the name of the organization for which they work or which they represent. We may also post video cameras in public-access areas on our premises;
  10. user names used by consumers on social media sites and comments/questions associated with those sites; and
  11. other information with your consent or as permitted or required by law.

Calls to and from JJI may be recorded and/or monitored for quality and training purposes. Recordings may also be used to help us develop and improve our products and services. Information may also be actively and passively collected by our web sites. See Technology Implications below for details.

Personal information we collect from you may be stored in the data bases of JJI, its affiliates or third party service providers, some of which databases may be located outside of Canada.

Purposes

JJI collects personal information for a variety of purposes relating to the operation of our business and the delivery of services to you, including to:

  1. provide our products and services and generally manage and administer our business including maintaining business records for reasonable periods and defending and bringing legal actions;
  2. develop and improve our products;
  3. develop and implement brand and consumer marketing programs that specifically tailor consumer offers or communications to your specific needs based on personal information that you have provided to us that indicates such things as your product or purchasing preferences or requirements;
  4. administer contests, promotions, surveys and web site chat rooms or applications and bulletin boards (e.g. Facebook wall posts);
  5. administer consumer satisfaction surveys to obtain feedback to improve the products and services we provide you;
  6. provide you with health and product-related information;
  7. reply or to clarify your requests, inquiries and comments;
  8. receive and assess product inquiries, reports of adverse events, and product complaints;
  9. assist in or co-ordinate product recalls;
  10. establish and maintain our relationship with healthcare professionals and administrators and other individuals with whom we have contact in the course of our business;
  11. provide assistance and advice to healthcare professionals and institutions with respect to our products;
  12. test and analyze our products for efficacy and safety;
  13. meet legal, regulatory, insurance, security, ethical and processing requirements such as adverse event and clinical reporting to Health Canada and regulatory bodies;
  14. monitor compliance with informed consent requirements when patients participate in clinical trials, and verify that clinical data collected by JJI in the course of the clinical trial conforms to the source data available at the site of the clinical trial;
  15. use feedback provided to us in the course of advisory board meetings to develop the strategic positioning of our products;
  16. manage, administer, collect and enforce accounts;
  17. provide remuneration to individuals who have performed services for JJI;
  18. enable us to act responsibly in the event of a health or other crisis or emergency and to enhance workplace security;
  19. evaluate resumes or other personal information submitted to us in connection with employment possibilities. For candidates who are not offered or do not accept a position, we may retain their information in the event that an appropriate position becomes available or that they re-apply to JJI.

JJI will limit the collection and use of both the amount and the type of personal information to that which is necessary to fulfill the identified purpose at the time of collection or as identified above. We may also use your personal information for other purposes that are disclosed at the time of collection with your consent or as permitted or required by law.

Disclosures - Use of Service Providers

We may transfer personal information to outside agents or service providers (including affiliates acting in this capacity) that perform services on our behalf, for example: certain payroll and benefits administration functions; receipt and administration of certain adverse event or product quality complaints; certain credit card, billing, mailing, marketing, fulfillment, contest management, administration of marketing promotions, information technology and/or data hosting or processing services, or similar services; or otherwise to collect, use, disclose, access, store or process personal information on our behalf for the purposes described in this Privacy Policy. Some of these service providers may be located outside of Canada, including in the United States. While outside of Canada, your personal information will be subject to applicable foreign legal requirements, which may include lawful requirements to disclose personal information to government authorities in certain circumstances. We take contractual or other means to ensure that your personal information that may be collected, used, disclosed, accessed, stored or otherwise processed by the service provider on our behalf is protected and not used or disclosed for purposes other than directed by us, subject to legal requirements in foreign jurisdictions applicable to those organizations.

Please refer to the Access, Correction and Contacting Us section below in order to find out how to obtain access to written information about our practices with respect to service providers outside of Canada and the title of the person who is able to answer, on behalf of JJI, questions you may have about a) the service providers outside Canada who may collect, use, disclose, access, store your personal information, b) the purposes for collecting, using, disclosing, accessing or storing your personal information, or c) where information will be held or the categories of persons who will have access to it.

Other Disclosures

JJI may also disclose your personal information in the following circumstances:

We may disclose personal information when required in order to meet legal, regulatory, industry self-regulatory, insurance, audit, security or ethical requirements, including obligations to health and drug regulatory and self-regulatory bodies, physicians, hospitals, or other healthcare facilities.

Your personal information may be used by JJI and disclosed to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of JJI's business or assets, including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction or business relationship and to fulfil reporting or audit requirements. Assignees or successors of JJI or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

We also may disclose your personal information to third parties, located in Canada and/or any other country, where required or permitted by applicable laws, court orders, or government regulations (including as required by Canadian and foreign laws applicable to JJI or our agents and service providers).

We may also disclose your personal information in other circumstances with your consent.

Consent

Consent to the collection, use and disclosure of your personal information may be given in various ways. Consent can be express (express consent may be oral, in writing or electronic), implied (such as when you provide your name and address in order for us to send you products or information you have requested) and may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with your personal information, we will assume that you consent to our collection, use and disclosure of such information as described in this Privacy Policy, if applicable, or as otherwise identified at the time of collection.

However, you may be asked to "opt in".

Opt In

In some cases you will, at the point of collection of the information, be given the option to "opt in". The act of "opting in" constitutes your express consent to receive future communications that may be of relevance to you. You can provide your express consent to our collection, use and disclosure of such information by checking a box on a form, clicking on a specified icon on a web site, or by doing some other specified action such as contacting us by telephone or by e-mail, or by signing a consent form on which your personal information is requested. Your personal information will in such case only be collected, used or disclosed for the purposes we describe at that time if you "opt in". You will, for example, have the option to "opt in" to receive information about, or special offers for, the products of JJI, in which case you will receive information relating to those brands and programs of JJI that we believe may be of interest to you. By "opting in" to offers from JJI, you are indicating your agreement to automatically receive communications regarding any brands or programs of JJI that we believe will be of interest to you. Alternatively, for certain brands or specific programs, where offered, if you wish to receive information relating only to specific brands and related programs or only to specific programs, you will have the option to "opt in" separately for these. After you "opt in" to receive offers or programs, you will have the option to "unsubscribe" or withdraw your consent if you no longer want to receive communications, either by following the instructions in an e-mail we send you or by contacting us by other means, as described below.

It is currently our policy, when collecting personal information that will be input into the JJI consumer database, to only to use that information for the purpose of sending communications and offers to consumers as described above. Unless you have indicated that you wish to receive specific program or brand information the information you provide will not be used to send you offers and communications outside of the initial interaction (e.g. registration, trial offer, contest, or coupon request).

When you wish to participate in a promotion, contest or survey, engage or participate in discussions, promotions or otherwise interact on our websites, or to purchase a product you will not be required, as a condition of your participation or purchase of the product, to provide more personal information than is necessary or legally required in order for us to administer the promotion, contest or survey, facilitate the discussion or to deliver any products you may be entitled or wish to receive. However, you may be provided with the option of providing additional personal information. You may, for example, choose to provide additional personal information by completing a questionnaire on a contest ballot relating to your use of our products, in which case we may then use that information to assist us in developing, improving, and selling our products or improve your interactions on our web sites.

Withdrawal of Consent

If you have provided us with personal information and wish to withdraw your consent to its retention, use or disclosure, please contact us as described below in the Access, Correction and Contacting Us section. You may withdraw your consent, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, maintaining reasonable business records and disclosures to Canadian and foreign government entities where required by law).

Exceptions

There are instances where we may be permitted or required by law to collect, use or disclose your personal information without your consent including, for example, to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

About Children

Children under the age of 13: We do not intend to collect personal information from individuals under the age of 13, unless expressly stated and with parental consent. We will not knowingly collect information from visitors to the web sites of JJI in this age group. If a child under 13 has provided us with personal information, we ask that a parent or guardian of the child contact us to request that this information be deleted from our records. We will use reasonable efforts to delete the child's information from our existing files. We encourage parents to talk to their children about their use of the Internet and the information they disclose to web sites or otherwise.

Security

We may establish and maintain a file of your personal information for the purposes described in this Privacy Policy, which will be accessible at our offices. Authorized employees, agents and mandatariesof JJI who require access to your personal information in order to fulfill their job requirements will have access to your personal information. We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information. JJI will take appropriate steps to ensure that personal information about you is protected from loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Although we have enacted security measures, we cannot guarantee the security of any information that you submit via email, chat applications or over the Internet. Submission of personal information using such networks is done at your own risk, since no Internet transmission is ever 100% secure or error-free (in particular, emails sent to or from our web sites may not be secure). You should take special care in deciding what information you send to us via email or posting on our web sites. Moreover, where you use passwords, ID numbers or other special access features on our web sites, it is your responsibility to safeguard them. Our web sites may contain links or references to other web sites to which this Privacy Policy does not apply. JJI is not responsible for the data collection and use practices of companies or organizations to which the JJI web sites may provide links. We encourage you to read the privacy statement/policy of every web site you visit.

Access, Correction and Contacting Us

You may contact us as described below in order to:

  1. receive a copy of the most current version of our Privacy Policy or our procedures regarding the use of third party providers outside of Canada;
  2. communicate any questions, comments, or concerns about our Privacy Policy or personal information handling practices or to request additional information;
  3. request to withdraw your consent to our retention, use or disclosure of your personal information;
  4. request access to or correction of your personal information;
  5. receive information or special offers;
  6. obtain access to written information about our practices with respect to service providers outside of Canada or get answers to questions you may have about a) the service providers outside Canada who may collect, use, disclose, access, or store your personal information, b) the purposes for collecting, using, disclosing, accessing or storing your personal information, or c) where information will be held or the categories of persons who will have access to it;
  7. Requests regarding item 4 above must be made in writing. Requests are subject to some access exceptions as prescribed by law and identified below under Access Exceptions. Any exceptions to providing you with access to your personal information must be approved by the Canadian Chief Privacy Officer.

We will take reasonable steps to verify your identity before granting access or making corrections. We will respond to you within thirty (30) days after the written request for access or rectification has been received or will notify you during that period if a longer period is required by us in order to fully address your request, provided that an extension of such thirty (30) day period is permitted by applicable privacy laws.

You may contact us by:

  1. writing to us at the following address

  2. Johnson & Johnson Inc.
    Attention: Canadian Chief Privacy Officer
    199 Grandview Road
    Skillman, NJ 08558-9418

  3. calling us at 1-800-265-8383 and asking to speak to Canadian Chief Privacy Officer
  4. emailing us at privacy@jnjcanada.com



You may also view a current copy of our Privacy Policy at www.jnjcanada.ca.

Access Exceptions

Some information may not be accessed in certain limited circumstances. In some cases, for example, the following exceptions may apply:

  • information that contains references to other individuals and such information is not severable from your personal information,
  • information the disclosure of which would reveal confidential commercial information, and
  • information that is subject to solicitor-client or litigation privilege.



The Canadian Chief Privacy Officer must approve all exceptions to access. The reasons for denying access shall be provided by JJI upon request.

Technology Implications

Active Information Collection

Our web sites may actively collect information from visitors both by asking you specific questions and by permitting you to communicate directly with us via email, chat applications and/or feedback forms. Some of the information that you submit on our web sites may be personal information.

Passive Information Collection

As you navigate through our web sites, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, web beacons and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the web site some of this interactive information, such as the URL of the web site you just came from and the Internet Protocol address and the browser version your computer is currently using. Our web sites may also collect interactive information from your computer through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of our web sites might not work without cookies.

Our web sites may use and combine such passively collected interactive information to provide better service to site visitors, customize the sites based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the sites for your use. Such information is not combined with personal information actively collected on our web sites unless you have consented.

We may use third-party services to make it easier for you to navigate links on our sites and social media sites (e.g. URL shorteners). These companies have their own privacy policies regarding data that passes through them when you click on those links. We encourage you to review those privacy policies before using those services.

Cookies

The following is a description of cookies and other passive tracking methods.

A "cookie" is a bit of information that a web site sends to your web browser that helps the site remember information about you and your preferences.

"Session" cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate and collect aggregate statistical information on the site. They are erased once you exit your web browser or otherwise turn off your computer.

"Persistent" cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the web site visitors find most valuable, and customizing the web site based on your preferences on an ongoing basis.

You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. To learn more about cookies and how to specify your preferences, please search for "cookie" in the "Help" portion of your browser.

IP Addresses and Tags

A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider. In most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.

"Internet tags" (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the web site server information such as the IP address and browser type related to the visitor's computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted.

"Navigational data" (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, for market research purposes, and to communicate information to visitors.

Privacy Policy Changes

This Privacy Policy may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this Privacy Policy, we will make reasonable efforts to notify affected individuals, if necessary, including by posting the revised Privacy Policy on our web sites. We recommend that you review this Privacy Policy frequently. Your continued provision of personal information or use of our web sites following any changes to this Privacy Policy constitutes your acceptance of any such changes.

When we update this Privacy Policy, it may not be possible for us to update all of our web sites simultaneously with the most recent Privacy Policy. We will, however, put the most recent version on our main web site (www.jnjcanada.com) first so that the most recent version can always be found there.


Last Updated: October 19, 2012