Welcome to ALK-Abelló Pharmaceuticals, Inc. (“ALK,” “us,” “we,” “our”).

This privacy policy (“Policy”) describes how we may collect, use, transfer, and disclose personal data (“PI”) or, on rare occasion, personally identifiable information (“PII”) that you provide to ALK on https://www.alk.net/ca/ (the “Website”) and during your other interactions with us where we have indicated that this Policy also applies. With the exception of limited, automatically collected information described in this Policy, you can use our Website and affiliated content without disclosing such information. You are not required to provide PI or PII as a condition of using this Website or another, affiliated page to which this Policy also applies, except as stated within this Policy (i.e., automatically collected information) or as may be necessary to provide you with information which is requested by you. If, however, you request information from our Website or ask us to resolve complaints or concerns, we may require certain information necessary to fulfill your request (e.g., your name, contact information, and other identifying information).

By voluntarily providing your personal data to us, by visiting our Website or an affiliated site, or by completing one of our forms, you agree to be bound by the terms of this Policy. If you do not agree to the terms of this Policy, please do not submit any personal data to us.

This Policy may be amended from time to time, in our sole discretion. When this happens, we will make available an updated version of the Policy, which will include the relevant changes. You are encouraged to review the Policy each time you voluntarily provide us with personal data or access this Website.
The following is a summary of the key elements of this Policy. You can read the full version of the Policy following the summary.

We may collect the following personal data when you provide it to us, register with us, complete forms or emails, inquiries or requests, or as otherwise stated in this Policy:

• Contact information (including your first name, last name and email address);
• Gender;
• Geographical location data;
• Behavioural analytical data; and
• Personal health information related to your allergy symptoms.

We may use Cookies, Google Analytics, and other similar technologies to collect your Website/affiliated content usage information, which is either not linked to your personal data, or aggregated into statistical reports which allows us to optimize Website content and the user experience.
We may use the personal data you provide us for the following purposes:

• To provide you with the use of our Website;
• To communicate with you via our newsletters or other electronic communications;
• To resolve your issues or to provide answers to inquiries;
• To improve, develop and provide a better personalized experience;
• To send you notifications;
• To ensure the Website remains functioning and secure;
• To present you with relevant content; and
• To comply with any applicable law and assist law enforcement agencies as required.

We may disclose your personal data to advertising, marketing, and analytics service providers, as well as independent third parties, our advisors, or other persons to whom we are authorized or required to disclose such information under relevant laws.

Contact Us:

For more information regarding our Policy, our privacy practices, or to obtain access to or correction of your personal data, please contact us at:
ALK-Abelló Pharmaceuticals, Inc. # 35-151 Brunel Rd., Mississauga, Ontario  L4Z 2H6; T: (+1) 800 663 0972; email Privacy Officer, Andrew Desbarats, General Manager of Canada or PrivacyNA@alk.net.

This Policy covers the following:

1. Consent
2. Collection and Use of Personal Data
3. Use of Cookies
4. Google Analytics
5. Disclosure of Personal Data
6. Security
7. Storage and Transfers of Personal Data Outside Canada
8. Retention of Personal Data
9. Children
10. How to Access and Correct Your Personal Data
11. Links to Other Websites
12. Updates to Privacy Policy
13. Questions, Complaints and Contact Information

We are open about the personal data we collect. We only collect, use, transfer, and disclose personal data with your consent or as otherwise permitted or required by applicable law.

We collect personal data only when you provide it to us, through registration, completion of forms or e-mails, inquiries, or requests, or as otherwise stated within this Policy (i.e., automatically collected information to the extent it is personal data). We encourage you to be mindful of “opt-in” and “opt-out” options, which are available to you on our Website and on affiliated pages and channels. If you choose not to provide any requested personal data, you may be unable to access certain areas of the Website or affiliated pages and channels, such as password protected areas.

It is always your choice whether to provide us with your personal data. We will retain control of and responsibility for the use of any personal data you disclose to us. Any personal data used by the Website will be accessible only by a discrete team of individuals responsible for administering the Website, as well as the third-party service providers of our systems and applications associated with the Website, as described in this Policy.

Personal data means any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. PII is defined as information: (i) that directly identifies an individual (e.g., name, address, identifying number or code, telephone number, email address, etc.) or (ii) by which an agency intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. These data elements may include a combination of gender, race, birth date, geographic indicator, and other descriptors. We may collect and process your contact information (including first name, last name, email address) when you provide such information in fillable forms or on our Website to receive our newsletter or other electronic communications from us, to resolve issues, or to provide answers to inquiries. You may notify us at any time that you wish to unsubscribe by either clicking on the unsubscribe link in our newsletter or other electronic communications, or by notifying us via the contact information in Section 13.

Cookies are used in order for us to improve the efficiency of your individual use of the Website. Cookies are small text file identifiers that are sent to your web browser and stored on your computer’s hard drive. Cookies allow the Website to remember your computer on return visits. This is particularly important for websites that require you to sign in as it speeds up your access. Websites may use session cookies that are deleted when you close your web browser, and persistent cookies, which may be used by the Website on subsequent visits. By default, we have implemented an opt-in, rather than an opt-out, mechanism for cookies.

If you select to opt-in, we may receive the name of your internet service provider, the website that you used prior to our Website, the websites that you visit from our Website, and your Internet Protocol address, among other information. This information is not linked to your personal data.

Most web browsers are set up to accept cookies automatically, but you can change the web browser’s settings to refuse new cookies, disable existing ones or let you know before new cookies are stored on your computer. However, if you refuse or disable cookies, some of the Website’s functionality may be lost. We may also include web beacons (also known as web bug, pixel tag or clear GIFs) on our Website or e-mails. Web beacons help us monitor the effectiveness of the Website by measuring the activity of the Website or how many users clicked on any elements of the Website. Web beacons do not automatically obtain personal data from you, but can tell us when you have opened your email or visited the Website. If you want to delete any cookies or web beacons that are already on your computer, or stop cookies or web beacons being stored on your computer in the future, see the “Help” section of your web browser.

In addition to the cookies and similar technologies set out in our cookie policy (referred to therein as “Other Information”), we use a Microsoft technology service called Clarity to analyze customers’ browsing patterns on this site. This technology enables us to understand our users’ experience and to improve our website. Clarity uses cookies and other technologies to collect data regarding our users’ behavior and their devices. The data collected includes technical data (including Internet Protocol addresses in anonymized form), geographic location data (i.e., the countries in which users sit), and language preferences). Clarity stores this information in an anonymized user profile. Neither Clarity nor ALK will use this information to identify individual users or to match the information with further data regarding individual users. For further details, please see Microsoft’s privacy policy by clicking on this link. Alternatively, click here to find out more about Clarity’s terms of use. You can opt-out of our cookies if you do not want your data to be collected for analytical purposes or to inform how ALK may improve your user experience.

We use Google Analytics to enhance how you interact with our website. Google Analytics provides web analytics services to track, monitor and report website traffic through collection of pseudonymous (i.e. de-identified) data about each visitor to our site. Information collected may include:

• IP address and general geolocation information
• Demographic data
• Language preferences
• Interests
• Browser type
• Operating system information
• Pages visited
• Traffic origin

Data collected by Google Analytics is stored by Google and shared with us in the form of aggregated reports that allow us to better understand how users interact with our website. Google Analytics may also share data with other Google services.

Google Analytics may use collected data to contextualize and personalize advertising. From time to time, we may also use Google Analytics remarketing functionalities, which use cookies stored on your device to display our ads when you visit other sites. You can opt-out of this kind of ad personalization by adjusting your preferences at https://adssettings.google.com/anonymous?hl=en.

You can opt-out of having your information tracked in Google Analytics by installing an opt-Out Browser Add-on. This add-on will prevent Google Analytics script from sending your user data to Google Analytics. For more information, visit https://tools.google.com/dlpage/gaoptout.

You can learn more about Google privacy practices by visiting https://policies.google.com/technologies/partner-sites.

We may retain third party vendors to assist us to perform our services. Such third party vendors may be provided with access to your personally identifiable information to perform their obligations pursuant to contractual obligations with us, but for no other purpose. We have set out below the categories of third parties to whom we will disclose your personally identifiable information. Where possible, we will provide you with more details about specific third parties, including third-party data processors and service providers, to whom we may disclose your personally identifiable information to provide services to us and for the purposes as outlined in this Privacy Policy.

a. Third-Party Advertisers or Remarketers

We may share Other Information about you with third parties, including, but not limited to, advertising and remarketing providers, or other brand partners, for purposes of personalizing or otherwise understanding how you engage with ads or other content. For example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. In addition, we may receive Other Information from these third parties, including through their service providers, such as advertising identifiers, IP addresses, and post-conversion data.

You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their targeted ads or other personalization features. Please note you will not necessarily be opted-out of advertising or content generally; you may still receive generic ads or content.

• For Instagram, please visit: Instagram: https://help.instagram.com/1896641480634370?ref=ig
• For Facebook, please visit: https://www.facebook.com/privacy/policies/cookies/?entry_point=cookie_policy_redirect&entry=0
• For LinkedIn, please visit: https://www.linkedin.com/help/linkedin/answer/a421454#:~:text=Manage%20your%20ads%20settings,-You%20can%20adjust&text=You%20can%20also%20opt%20out,page%20under%20the%20Messages%20section.

b. ALK Employees, External Processors and Service Providers

The recipients of any personal data you disclose to us will be our employees as well as external data processors processing your personal data on our behalf and external service providers providing specific services to us. They will be given access to your personal data, if at all, only on a ‘need-to-know’ basis in order to fulfil their duties and/or contractual obligations, being subject to the obligations of confidentiality under internal ALK policies and/or after signing appropriate legal documents, where relevant.

c. Independent Third Parties

We may disclose your personal data to our lawyers and other persons to whom we are authorized or required to disclose under relevant laws. We may disclose your personally identifiable information to comply with any court order or legal obligation, including responding to any lawful government or regulatory request, or if we believe disclosure is necessary to enforce or protect our or a third party’s rights, property, or safety. We may disclose your personal data in the event of or during a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of our assets or equity, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personally identifiable information held by us is among the assets transferred. Additionally, we may disclose your personally identifiable information for any other purpose disclosed by us when you provide the information or as otherwise permitted or required by applicable law.

We use reasonable physical, technical and organizational security precautions to protect your personal data from manipulation, loss, destruction or access by unauthorized persons. Any personal data that is provided to us by you will be encrypted in transit to prevent its possible misuse by third parties. We have a number of relevant internal privacy policies, procedures, and guidelines and we also make sure that we have appropriate non-disclosure, data processing and other appropriate agreements and provisions in place, so that your information is adequately protected. Our security procedures are continuously revised based on new technological developments.

Due to the nature of Internet communications, we cannot guarantee that such communications are 100% secure or error-free and disclaim that the information you provide us will remain free from theft, loss, or unauthorized access or use by third parties, despite our best efforts. You are responsible for maintaining the privacy of any usernames, passwords, or other special access numbers you might use to access the Website.

Where a data transfer impact assessment (DTIA) demonstrates that the personal data would be adequately protected, including with respect to generally accepted privacy principles, we may store, process and/or transfer your personal data outside your jurisdiction of residence. Consequently, your personal data may be subject to local laws of the jurisdiction to which it is transferred, and it may be accessible to local governments, tribunals, law enforcement and regulatory agencies. The personally identifiable information we collect from you is generally stored on cloud-based servers hosted throughout Europe and North America.

We will retain your personal data only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. As such, we may keep your account information after the termination of your account.

Children under the age of 16 are not the intended audience for the Website. In light of the importance of protecting children’s privacy, we do not knowingly collect personal data from this age group without prior parental or legal guardian consent.

If you wish to exercise any of your rights under this Policy, please submit a written request to us at our contact information in Section 13. In some situations, we will also be able to give you access to modify and download your personal data and to adjust your privacy preferences online via a secure connection.

Withdrawing Consent: If you have given consent to the processing of your personal data for one or more purposes, you are entitled to withdraw your consent at any time (without affecting the lawfulness of any information processing that took place before the withdrawal of consent).
Access and Rectification: You may access personal data which we hold about you, correct any inaccurate personal data about you and/or complete any incomplete personal data about you. You are entitled to access your personal data, subject to the restrictions on access that are set out in relevant laws and subject to the photocopy fees applicable under relevant laws, where permitted. We may require you to verify your identity before we allow you to access your personal data.
Additional Rights: Under certain circumstances and subject to applicable data protection laws, you may also be entitled to request additional information regarding our data governance practices, including details regarding what information is collected about you, the categories of persons who have access to your information, and how long your information will be retained for. You may also be entitled to request that we cease communicating your information, or de-index any hyperlink attached your name that provides access to your personal data by a technological means.

We may provide links to, or automatically produce search results for, third-party websites or resources, or third-party information referencing or linking to third-party websites or resources. We have no control over such third-party websites and resources, and you acknowledge and agree that we are not responsible for the content or information contained therein. When you follow such a link, you are no longer protected by our Policy, and we encourage you to read the privacy statements or other disclaimers of such other parties. We are not responsible for the privacy or security practices or the content of external websites, services or products.

Again, we reserve the right to modify our Policy at any time so please review the Policy each time you access the Website. Material changes will be indicated on the revised Policy. Any changes will be effective immediately as of the updated revision date indicated above.

If you have any questions or comments regarding our privacy practices, procedures and guidelines or those of our domestic or foreign third-party data processors or service providers, please do not hesitate to contact us at:

ALK-Abelló Pharmaceuticals, Inc. # 35-151 Brunel Rd., Mississauga, Ontario  L4Z 2H6; T: (+1) 800 663 0972; email Privacy Officer, Andrew Desbarats, General Manager of Canada or PrivacyNA@alk.net.

If you are not satisfied with the way your personal data is handled, with the information you receive, or with any other aspect relating to the protection of your personal data, please reach out directly to us using the contact details above. If we are unable to resolve your privacy concerns, you have the right to complain to the Office of the Privacy Commissioner of Canada or the relevant Information and Privacy Commissioner in your jurisdiction of residence.