Columbia Laboratories Canada, Inc.

Privacy Policy

At Columbia Laboratories Canada, Inc. (“Columbia Labs”) we take seriously our responsibility to protect any personal information that is in our control. “Personal information” is information about an identifiable individual, such as your name, address, email address, or phone number. It also includes comments or inquires you have made about our products or services when such comments or inquiries are linked to you.

This privacy policy adheres to the principles set out in Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and similar provincial privacy legislation. It applies to individuals who deal with us in Canada including consumers, health care professionals, pharmaceutical representatives or others within the health care or pharmaceutical industries. It does not apply to information about our employees or to information that is not personal information.

Policy

The policy of Columbia Labs is to respect and protect the privacy of our users. To fulfill this policy, Columbia Labs agrees to exercise the precautions set forth in this Privacy Policy to maintain the confidentiality of information provided by you in connection with accessing and using the Columbia Labs website or social media sites (the “Website” or the “Site” or “Sites”). When you provide personal information to us through any of these Sites, you agree with the terms of this Privacy Policy and consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.
Collection of Information

Columbia Labs only collects personal information about individuals when specifically and knowingly provided by such individuals. For example, when you register for our Benzagel® newsletter, you will be asked to provide personal information such as your name, postal code, e-mail address, date of birth, gender, and/or phone number. Registering on the Columbia Labs website, and/or our subsequent social media sites, may allow you to participate in various activities on the Site such as taking advantage of promotions, entering contests or sweepstakes, responding to surveys, uploading videos, posting messages or subscribing to e-newsletters or other mailing lists. Columbia Labs uses the Site to provide Columbia Labs's services.
Disclosure of Information

We may transfer personal information to outside agents or service providers that perform services on our behalf. For example, mailing, marketing, contest management, administration of marketing promotions, or similar services. We take the necessary precautions 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. In addition, we may disclose your information to third parties, but only:
1. In connection with the sale, assignment, or other transfer of the business of this Site to which the information relates, in which case we will require any such buyer to agree to treat it in accordance with this Privacy Policy; or
2. Where required by applicable laws, court orders, or government regulations; or
3. When we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) the rights of Columbia Labs or to anyone that could be harmed by such activities.
In addition, we will make full use of all information acquired through this Site that is not in personally identifiable form.
Opt-Out Procedures

You can unsubscribe from receiving marketing communications from us by clicking on the unsubscribe link in any email marketing communication found at the bottom of each email or you can send an e-mail to consumercontact@columbialabs.ca with the word “Remove” in the subject line. Further, if you do not want your personal information shared with third parties in the manner discussed in Section 3, “Disclosure of Information,” please notify our Chief Privacy Officer at Columbia Labs through the contact information in Section 10, “Contact Us” below.
Security of Information

Personal information collected through the Site is secure and is maintained in a manner consistent with current industry standards. Your personal information is protected in several ways. For example, your personal information resides on a secure server that only selected Columbia Labs and contractors have access to via secure password. We also encrypt your personal information and thereby prevent unauthorized parties from viewing such information when it is transmitted to us. Unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that:
1. There are security and privacy limitations of the internet which are beyond our control;
2. The security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed; and
3. Any such information and data may be viewed or tampered with in transit by a third party.
Passive Information Collection

When navigating through a website, certain information can be passively collected using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, Google Site Stats, and navigational data collection. This Site may use Internet Protocol (IP) addresses to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, and administer and improve services to our consumers.

This Site uses session cookies and Google Site Stats to improve navigation on websites and to collect aggregate statistical information. This Site also uses persistent cookies to store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., username), helping to determine what areas of the website visitors find most valuable, and customizing the website based on your preferences.

This Site uses internet tags to tell the website server information such as the IP address and browser type related to the visitor's computer. This Site also uses navigational data and Google Site Stats for system management, to improve the content of the site, market research purposes, and to communicate information to visitors.
Links

This Site may contain links to the websites of third parties not affiliated with Columbia Labs. Columbia Labs does not control the content or the privacy policies of third party on-line resources to which our websites may provide links and this Privacy Policy does not, therefore, apply to any such resources.
Our Commitment to Children's Privacy

Protecting the privacy of the very young is especially important. We never collect or maintain information at the Site from persons we know to be under age 13, and no part of our Site is designed to attract anyone under age 13. Please do not communicate with or contact us if you are under age 13 without the consent of a parent or guardian.
Changes to this Privacy Policy

This Privacy Policy may change over time. Columbia Labs, Inc. will notify you by e-mail or letter to your last known address whenever we make any substantive changes to this Privacy Policy. If you do not accept the changed version (for example, if you do not approve of a different way that we intend to use personal information) you may let us know by letter or e-mail. Our contact information is provided below. If you do not respond with any objections, we will assume that you consent to changes in the Privacy Policy. Changes will not apply retroactively to personal information that was collected before the changes to the Privacy Policy, except as may be required by law.
Contact Us

You can contact us directly to learn if we are keeping personal information about you. If Columbia Labs does have personal information about you, we will provide you with a readable copy of such personal information at your request.

You may also request a Notice of Information-Sharing Disclosure which will identify the third parties with whom Columbia Labs has shared the information we have collected from you in accordance with this Privacy Policy. We will respond to your request for a Notice of Information-Sharing Disclosure within thirty (30) days of receipt.

Factual errors in your personal information, including information that is out of date, can be corrected by sending us a request that sufficiently details how your personal information should be corrected. We encourage you to promptly update your personal information with us if it changes.

You can contact our Chief Privacy Officer at the address below:

Columbia Labs, Inc.
2625 Regina Street Suite 408
Ottawa, ON K2B 5W8
Attn: Chief Privacy Officer.

You may also contact us via e-mail at consumercontact@columbialabs.ca or by telephone at toll-free 1-888-566-6682.