Last update: October 18, 2024
At Neurenati Therapeutics Inc (“Neurenati“, “we”, “us“), we respect your privacy and are committed to maintaining your trust, which is why we have implemented a privacy program and appointed a Privacy Officer to respond to your questions, comments and complaints regarding your privacy.
Neurenati is a pioneering biotechnology company developing an innovative treatment for Hirschsprung’s disease.
The purpose of this privacy policy (the “Policy“) is to describe our privacy practices regarding the collection, use, storage, sharing and protection of your Personal Information by Neurenati, including for our Employees and when using our website (the “Site“).
For the purposes of this policy, an “Employee” means any person employed by Neurenati, whether paid or unpaid, and includes, but is not limited to, a salaried worker, temporary worker, intern, volunteer, student, director, officer, agent, consultant, collaborator or other position holder.
The information contained on our Site is intended for healthcare professionals and other organizations involved in drug development, to give them more information about Neurenati’s activities. It is not a channel for communication with patients, who will be automatically redirected to a healthcare professional if they contact us.
Personal Information
For the purposes of this Policy, “Personal Information” means any information about an identifiable individual, including any information that directly or indirectly identifies such individual.
Personal Information Management
In order to protect Personal Information, we have put in place policies, practices and procedures relating to the management of the Personal Information we hold.
These internal policies and procedures govern the collection, use, disclosure, retention and destruction of Personal Information, as well as the handling of complaints, information security and data governance at Neurenati. They also provide the framework for the implementation of Privacy Impact Assessments, where required, as well as the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer.
Neurenati’s collection of your Personal Information complies with the requirements of this program.
Privacy Officer
The management of the privacy program is the responsibility of our Privacy Officer. His duties include the internal management and monitoring of Neurenati’s privacy program.
It is the Privacy Officer who approves and implements the privacy policies and procedures, ensures their proper functioning and reports to Neurenati’s senior management on the effectiveness of the program.
It is also the responsibility of the Privacy Officer to provide you with the necessary support in the event of a question, complaint or request relating to the protection of Personal Information:
General Manager, Chairman of the Board and Privacy Officer
Neurenati Therapeutics Inc.
141 President-Kennedy Avenue
Montreal (Quebec) H2X 1Y4
info@neurenati.com
We are committed to responding promptly to your requests.
Upon receipt of a complaint, the Privacy Officer will conduct an investigation. If the complaint is justified, the situation will be corrected. Regardless of our conclusion, we will keep you informed.
Basis for processing Personal Information
Neurenati must collect and process certain Personal Information in order for you to use our Site and in the course of your duties.
When we collect your Personal Information, we ensure that we collect only the information necessary to fulfill one of our purposes, which has been previously disclosed to you, for example, in this Policy. We use Personal Information in accordance with the privacy laws applicable to our business.
The following is a description of the basis on which Neurenati collects and processes your Personal Information:
Your consent
As required by applicable privacy legislation, Neurenati collects the majority of your Personal Information on the basis of your voluntary consent, favouring collection directly from you.
For example, Neurenati undertakes to obtain your explicit consent for the collection of any Sensitive Personal Information.
Neurenati mainly collects Personal Information from Employees directly from them, with their consent. This consent allows Neurenati to manage all aspects of the employment relationship. Once consent is given, unless it is subsequently withdrawn, Neurenati considers that the Employee has consented to the continued access, use, disclosure and retention of Employee Personal Information until the end of the employment relationship.
Other permissible legal basis, such as the performance of our contracts
As permitted by applicable privacy laws, Neurenati may collect Personal Information without your express consent, for example, to comply with our obligations under applicable laws or to fulfill our contracts.
Personal information collected
Depending on the nature of your activity on the Site or in the course of your duties, we may collect your Personal Information, including;
Purposes of collecting Personal Information
We only collect the Personal Information That we consider necessary for the following purposes;
(i) to protect our operations and legitimate interests or those of our subsidiaries;
(ii) to enable us to pursue available remedies or limit the damages we may suffer, etc.
If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will ensure that we seek appropriate consent from you or inform you of the change, where permitted by law.
Disclosure of Personal Information
Your Personal Information will not be sold to third parties.
We share your Personal Information with third parties to (i) fulfill our purposes, (ii) respond to requirements or requests made under applicable laws, (iii) perform tasks contracted to us by our customers.
Most oh the time, you have already consented to such sharing. Sometimes applicable laws also allow us to share your Personal Information with third parties without your consent, in specific cases.
Specifically, we may need to share your Personal Information, sometimes without your consent:
With our Employees
In the course of their work, our employees and officers may have access to your Personal Information, for example when you contact us through our Site. Access to Personal Information is limited to that which is necessary for the performance of their respective duties.
With our service providers
Our business partners may need to access or receive certain Personal Information in order to perform their services (cloud data hosting, maintenance, analysis and development). In such cases, we implement reasonable contractual and technical safeguards, including Privacy Impact Assessments, to ensure that these third parties keep all Personal Information they process strictly confidential.
Please note that these third parties may not be located in your country, province or territory of residence. For more information on this subject, please see “Third parties located abroad”.
With authorities or persons authorized by law
We may share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to:
Complying with the law;
With potential buyers of our company
We may need to share your Personal Information without your consent in the event of a merger, acquisition or sale of all or part of the business, for example, as part of a due diligence review. In such a case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction.
Third parties abroad
Your Personal Information may be disclosed and stored outside your province, state, territory or country of residence.
Our business partners and service providers may be located in Canada or other countries. Please be aware that we have contractual agreements with these third parties and suppliers to ensure that your Personal Information is handled in accordance with the laws applicable to us. Where applicable, we conduct Privacy Impact Assessments prior to any transfer of Personal Information to another jurisdiction, such as outside Quebec.
Retention and destruction of Personal Information
Neurenati will retain your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected, in accordance with our internal document retention policies, to comply with applicable legal, tax or regulatory requirements. After the specified retention period, any Personal Information concerned and held by Neurenati will be destroyed, deleted or anonymized.
Security
The security of your Personal Information is a priority for us.
Your Personal Information is hosted by our service providers who are committed to using reasonable security measures to preserve the integrity and confidentiality of your Personal Information.
Our employees and suppliers are informed of the confidential nature of the personal information collected and are made aware of the appropriate security measures to prevent unauthorized access to personal information.
We maintain our Site and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorized access, destruction, misuse, alteration and improper disclosure of your Personal Information. These safeguards vary according to the sensitivity of the data in our possession, and are based on the best industry standards. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
If you have any questions about the security of your interaction with us, you can contact us at info@neurenati.com.
Your rights regarding your Personal Information
Depending on applicable laws, where you live, your employment relationship with us or how you interact with the Site, you may have certain rights with respect to the Personal Information we hold about you.
For example, you may be entitled to:
File a complaint
You may file a complaint with Neurenati’s Privacy Officer if you are dissatisfied with our handling of your Personal Information or compliance with this Policy.
You are also entitled by law to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of Personal Information.
Exercising your rights
You can exercise your rights listed above by sending a written request to our Privacy Officer. He will be able to help you with your request, should you need it.
We may need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any. We aim to respond to requests promptly, usually within 30 days.
In the context of the processing activities covered by this Policy, Neurenati does not make decisions based solely on automated processing producing legal effects or similar significant effects.
Your choices regarding our use and disclosure of Personal Information
The Information you provide may be used by Neurenati for marketing purposes, including, but not limited to, one-time promotional e-mails, direct mailings and business contacts. We offer you several choices regarding our use and disclosure of your Personal Information for marketing purposes, or Cookies. You may opt out:
Cookies
A Cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. This Policy includes in the term “Cookie” other tracking technologies, including but not limited to web beacons and tracking pixels. These tracking technologies are not necessarily stored on your computer or device. Any Personal Information we collect using Cookies or on our behalf is treated with the same level of confidentiality as any other Personal Information we hold.
These Cookies are necessary for the operation of the Site and provide basic functions and may include maintaining your current browsing session and preventing security threats. We cannot disable these Cookies in our systems without affecting the operation of the Site. However, if you wish, you can block or delete them by changing your browser settings and forcing all Cookies on the Site to be blocked.
Non-essential Cookies provide certain non-essential functionalities on our Site, for functional, analytical or advertising purposes. We will ask for your consent before using these Cookies.
You can manage and deactivate Cookies through your browser’s Cookie settings and your mobile device’s advertising settings. However, if you refuse Cookies, you may not be able to use all of the Site’s features and you will continue to receive advertising, but it will no longer be as tailored to your needs.
Your online advertising choices
We may collect your Personal Information to offer you advertisements about goods and services and may work with online advertising companies to present you with relevant and useful advertisements. This Personal Information is collected directly from you.
We may also use your mobile advertising ID to target and measure the effectiveness of advertising campaigns. On iOS, this identifier is called “IDFA” (ID For Advertising); on Android (Google Play), this identifier is called “AAID” (Android Advertising ID).
You can control the collection and use of online advertising by expressing your preferences in your mobile devices. You can also control the use of your mobile advertising ID by resetting the IDFA or AAID or restricting its use in your mobile device settings.
Changes to this Privacy Policy
We revise the Policy from time to time to comply with applicable laws and our operations. If we update this Policy in a material way, we will notify you by sending you a notice on our Site. In all other circumstances, the posting of a new version of the Policy on our Site or your continued use of the Site will suffice as notice and consent to Policy changes.