Privacy Policy
Effective July 1, 2010:
We Respect Your Privacy
Thank you for your interest in QLT Ophthalmics, Inc. (referred to as 'QOI,' 'it,' 'we,' 'us,' or 'our'). Your privacy is important to us. This Privacy Policy explains what information we collect, how we collect it, and what we do with it. This Privacy Policy governs all sites in these domains: visudyne.com and qltinc.com.
Information We Collect
Browsing the Website
We keep track of the actions you take on the website, such as using our interactive services or viewing different pages, and we collect broad statistical data based on aggregate use of our website by our visitors. We do not use this data by itself to identify you personally, although we may link it to personally identifiable information that you voluntarily provide to us. We do not collect personally identifiable information from web visitors who do not volunteer to provide such information to us.
Voluntarily Submitting Personally Identifiable information
We may ask you for personally identifiable information, including health-related information, when you apply for access to certain special features or areas of our website, use interactive services such as health questionnaires, or communicate with us by email or otherwise regarding your experience concerning Visudyne® or our other products. Personally identifiable information may include, but may not be limited to, your name, address, phone numbers, email address, and concerns or questions regarding Visudyne or our other products.
If you are reporting a product experience, we may ask you for specific facts, including patient initials, age, and gender, and the prescribing physician. Federal regulations require us to collect patient-identifiable information in order to file reports regarding the safety of our products with the U.S. Food and Drug Administration and equivalent regulatory agencies in other countries.
How to Access and Update Your Information
Upon written request from you, we will inform you about your personally identifiable information that we have in our possession and control, and we will give you reasonable access to that information. You may contact QOI or write to us at the address below and request at any time to review, amend or delete (in accordance with our deletion policy described below) your personal information collected by us, and request that we stop collecting personal information from you in the future.
Privacy Officer
Legal Department
QLT Ophthalmics, Inc.
1098 Hamilton Court
Menlo Park, CA 94025
Deletion Policy
The information that you provide to us is stored in servers that are operated and maintained by QOI and/or our affiliated companies and with third parties under contract with us. Website users should be aware that it is not technologically possible to remove from our servers each and every record of the information you have provided to us. Upon receiving your request, we will take commercially reasonable steps to delete all personally identifiable information, including health-related personally identifiable information, stored in the databases we actively use, or that are stored in other readily searchable media. However, the need to back-up our systems to protect information from inadvertent loss means that a copy of information about you or personally identifiable or health-related information may exist on back-up tapes or in a non-erasable form that will be difficult or impossible for us to locate. We will use commercially reasonable efforts not to disclose any personally identifiable information, including health-related information, stored on back-up tapes or in a non-erasable format after receiving your request for removal, except as required by law or regulation.
Because of regulations and reporting requirements of the U.S. Food and Drug Administration and equivalent regulatory agencies in other countries, QOI may not comply with a request to amend or remove information that was provided to us regarding an adverse drug event with respect to Visudyne or one of our other products.
How We Collect Information
Website Interactions
Like many standard website service providers, we collect aggregated or non-personally identifiable information, including internet protocol (IP) addresses, browser and operating system types, and internet service providers (ISPs). We may also place cookies on your computer when you visit our website. We use cookies, which are pieces of data on your computer tied to information about you which recognize you as a return user of the website and help to provide a more personalized experience, and other similar technologies for similar purposes. We may use cookies to collect information from you, including your interest in health care conditions. Furthermore, we may associate any data about you collected from cookies, interactive tools, or any other information you disclose, with the personally identifiable information that you submit to us via our website. If you wish to turn off cookies, please see the "Turn Off Cookies" section below, though this may affect the quality of service we can provide you.
Email
QOI may use and disclose personally identifiable information which you provide to us by email for the purposes and to certain persons (please see the "How We use Information Collected From You" and "Sharing of Your Information" sections below). However, please be aware that email transmissions are vulnerable to unauthorized interception, and that we make no warranty, express, implied, or otherwise, that we can prevent unauthorized interception or access to any emails you send us or emails which we send to you.
Security
QOI will take measures consistent with industry practice that we believe are reasonably appropriate to protect your personal information, including using commercially reasonable encryption practices and physical placement of personally identifiable information behind industry-standard firewalls. Although we take reasonable steps to protect and to prevent unauthorized access to your personal information provided to us, we cannot be responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied, or otherwise, that we can prevent unauthorized access to your private information.
How We Use Information Collected from You
Personally Identifiable Information
QOI and its affiliates may use personally identifiable information for the following uses:
- in connection with the products and services we, our affiliates, or other third parties as described below, provide to you (for example, in connection with our interactive tools and questionnaires);
- to enhance the products and services we, our affiliates, or other third parties as described below, provide to you (for example, presenting content and features likely to be of greater interest to you);
- to help us and our affiliates direct our current and future research and marketing efforts on our or our affiliates' current or future products;
- for our and our affiliates' internal records, tracking and business purposes;
- to contact you or have our affiliates contact you to respond to your questions or requests, or to provide you with technical support;
- to, or to permit our affiliates to, process enquiries and instructions;
- to, or to permit our affiliates to, provide newsletters, special offers and occasional mailings (electronically or by mail) from us or our affiliates; and
- to otherwise facilitate and enhance your use of our or our affiliates' websites.
Non-Personally Identifiable Information
QOI and its affiliates may use non-personally identifiable information for the following uses:
- to improve our and our affiliates' products and services;
- to help us and our affiliates direct our current and future research and marketing efforts on our or our affiliates' current or future products;
- to customize the user experience of our or our affiliates' websites;
- to administer, upgrade, and protect our or our affiliates' websites, email servers, and other computer systems;
- to analyze trends, track user movement and habits, and gather statistical information for aggregate use;
- to improve our or our affiliates' websites in general; and
- to customize advertising and other marketing communications that may be visible to you on our or our affiliates' websites or from the websites of our marketing partners with links from our site.
Please note that, in addition to the above, we may share both personally identifiable and non-personally identifiable information with government entities, our affiliates and third parties, as described below in "Sharing of Your Information."
Sharing of Your Information
Government Entities
QOI may disclose your personally identifiable information when compelled or requested to do so by law enforcement or government authorities, pursuant to a subpoena or other legal process, or when we have a good faith belief that disclosure is otherwise necessary or advisable. For example, we share personally identifiable information with the U.S. Food and Drug Administration and equivalent regulatory agencies in other countries as required by law or regulation. If we share information in those situations, unless we believe that the information is already required to be treated confidentially by the government agency receiving the information, to the extent we have the legal right to do so, we will take commercially reasonable or appropriate measures to ensure that the party receiving your personally identifiable information understands the sensitive nature of the personally identifiable information, including health-related information, they may receive.
Affiliates
QOI may share both your personally identifiable and non-personally identifiable information (including your health-related information) with our affiliates (which includes our parent company, any subsidiaries, or other companies or entities under common control with us), in which case we will require such parties to honor this Privacy Policy with respect to all such shared information. Each of our affiliates will have the right to use and share your personally identifiable and/or non-personally identifiable information for the same purposes and with the same entities as we have the right to do under this policy.
Third Party Marketing Partners
QOI may share your personally identifiable and/or non-personally identifiable information (but not including health-related personally identifiable information) with selected third party marketing partners for marketing purposes, including offering you products or services of interest. We may share your health-related personally identifiable information with our third party marketing partners strictly for medical and product safety purposes. We will not share your health-related personally identifiable information for marketing purposes unless we provide clear notice to you and obtain your explicit consent to do so. If you have consented to such sharing and you later wish for us not to share further information with our marketing partners, you may opt out of future sharing as described in the "Your Sharing Options" section below. We require our marketing partners to protect the confidentiality of personally identifiable information received from us in at least as protective a manner as is provided under our Privacy Policy.
Third Party Service Providers
QOI may share your personally identifiable and/or non-personally identifiable information with selected third party service providers who perform services on our behalf, including, but not limited to, technology maintenance, fulfillment of business transactions, marketing assistance, email delivery, hosting services, customer service, and data analysis. We may share your health-related personally identifiable information with our third party service providers for IT-related and other administrative services and in connection with medical or clinical matters. However, we will not share your health-related personally identifiable information with our third party service providers for other purposes unless we provide clear notice to you and obtain your explicit consent to do so. If you have consented to such sharing and you later wish for us not to share further information with these service providers, you may opt out of future sharing as described in the "Your Sharing Options" section below. Our third party service providers are not permitted to use your information in any manner inconsistent with this Privacy Policy or for any purpose other than to provide services to QOI.
Additional Sharing
QOI reserves the right to use any personally identifiable or non-personally identifiable information in connection with a corporate audit, complaint or security threat, or in order to protect or enforce our rights, or the rights of our affiliates, customers and marketing partners. Furthermore, we reserve the right to provide non-personally identifiable information in aggregated form to any third party for any purpose.
In the event QOI undergoes a business transition, such as a merger, acquisition by another company, or sale, assignment, or other transfer of all or a portion of our equity and/or assets, we reserve the right to transfer your information, both personally identifiable and non-personally identifiable, to the successor organization in such transaction.
Your Sharing Options
Opt-out
If you elect not to receive newsletters or other promotional communications from us or our marketing partners or you wish to prevent us from sharing your personal information with any marketing partners in the future:
- You may opt-out of future marketing communications received from us or our marketing partners by following the steps described in each such marketing communication.
- You may also send an email message to medaff@qltinc.com
or contact QOI with a request to cease receipt of some or all future marketing communications.
Please note that once we receive your request, it may take up to 10 business days for such opt-out to become effective. If we have shared your personal information with any third parties prior to our receipt of your request, we may not have the ability to prevent such third parties from continuing to use and disclose your personal information, including for the purpose of sending marketing communications to you, and you may need to contact such third parties directly to prevent their further use and disclosure of your personal information.
Also note that if you opt-out of our marketing communications we may still email or communicate with you from time to time if we need to respond to your enquiries, provide you with information or request information from you with respect to a transaction or product report initiated by you, or for other legitimate non-marketing reasons.
Turn Off Cookies
Our web servers use cookies on a number of pages on the website and allow us to tailor the content that we present to you online and in emails. If you do not want your cookie information to be associated with your visits to these pages, then you may set your browser to turn off cookies. If you turn off cookies, then we will still detect an anonymous visit.
Please note that cookies are required to use certain features of this website. Therefore, if you turn off cookies, the performance of the website or our ability to provide you our services may be affected.
Our Policies Concerning Children
This website is not intended to attract or be used by children under the age of 13 and we do not knowingly collect any personal information from such children. Children under the age of 13 should not use our website or our online services at any time. In order to afford children additional protections and to comply with applicable laws, we have instituted additional privacy protections and controls regarding the collection of personally identifiable information from children in accordance with the United States' Children's Online Privacy Protection Act (COPPA). Specifically, in the event that we learn that we have inadvertently gathered personally identifiable information from children under the age of 13, we will use reasonable efforts to erase such information from our active records in accordance with the "Deletion Policy" section above and to unsubscribe such children from any promotional contact opportunities. If your child has provided any information or used your credit card on our website without your permission, please contact QOI immediately.
External Links
This site may, from time to time, provide links to sites operated by third parties. These sites are governed by different privacy policies, or may not have privacy policies. If you connect to a different site from our website, you should review the privacy policy of that site, which will govern any collection of information on that site. If you have any questions about how these other sites use your information, you should contact them directly. QOI cannot be held responsible for personal information you voluntarily disclose to third parties.
CA Compliance
This Privacy Policy describes when and how we share information for marketing purposes. This Privacy Policy applies to all users of the website, including residents of California. You can prevent future disclosures of your personal information for marketing purposes to our affiliates, third party service providers and marketing partners, at no charge, by exercising your opt-out rights as described in the "Your Sharing Options" section above.
Because we provide you with the ability to exercise such opt-out rights, we believe that we comply with the California Civil Code Section 1798.83, and we therefore are not obligated to provide the names and addresses of third parties that have received personal information from us for their marketing purposes.
When you provide us with your information you acknowledge that this information may be stored and processed on servers located any where in the world, including either inside or outside of the USA, Canada or the European Economic Area.
Updates and Questions
This privacy policy is subject to change. This page will be updated to reflect any such changes.
If you have any questions about our privacy policy, please contact QOI
Visudyne is a registered trademark of Novartis AG.