DATA PRIVACY POLICY
Effective Date: February 18, 2025
Our Commitment to Privacy
This Privacy Policy explains how we handle the personal information you provide to UCB, Inc. (UCB) within Canada, including our Canadian subsidiaries and affiliates which link to this Privacy Policy through their websites. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Policy covers only those activities that are subject to the applicable provisions of Canada’s federal and provincial privacy laws.
This Policy applies to any personal information that is collected by us, whether it is collected over the telephone, in writing, or electronically including through any of our websites, mobile application, or other digital platform, online product or service that links to this Policy (“Websites” or “Sites”). As used in this Privacy Policy, “You” or “Your” refers to users of a UCB Website or individuals who otherwise provide their personal information to UCB. “We” or “Us” includes UCB and its related companies. For offline interactions with UCB, this policy supplements (but does not replace) any other policy or notice provided to You as part of Your offline interaction(s) with Us. This Privacy Policy does not apply to third-party websites to which UCB Websites may link.
Consent
Your use of UCB Websites is subject to this Privacy Policy, any referenced Legal Notice, and any referenced Terms of Use. By using a Website and/or providing Us with Your personal information, You agree with the terms of this Privacy Policy in addition to any other posted policy found on the Site, and as permitted or required by applicable law. If You do not consent, please do not use our Sites or otherwise provide your personal information to us.
We may update this Privacy Policy from time to time and will post any changes we make on this page, effective upon our posting of the new terms. We include the date the Privacy Policy was last revised at the top of the page. If we make material changes to how we treat personal information, we will post a notice on the homepage of the Site and email notice of the change to registered users of our Site, where applicable. You are responsible for ensuring we have up-to-date, active, and deliverable contact information for you, and for periodically visiting this page to check for any changes. In all cases, your continued use of our services after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy.
About children
Unless specifically stated, no UCB Website is intended for persons under the age of 13. We will not knowingly collect personal information from Website visitors unless You have indicated that You are age 13 or older by submitting personal information to Us. If we learn we have collected or received personal information from a person under that age without parental/guardian consent, we will delete that information. We encourage parents to talk to their children about their use of the Internet and the information they disclose via the Internet.
Personal information
“Personal information” means any information about an identifiable individual. This includes information that we can reasonably use on its own, or with other information, to directly or indirectly identify an individual. Personal information generally does not include business contact information, including your name, title, or business contact information. Although the types of personal information We collect and share depend on the nature of Your relationship with UCB, as well as requirements of applicable laws, below are general categories of personal information that we may collect (either directly or indirectly).
All the below categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Direct information collection
In general. We collect and store personal information You enter on our Websites or otherwise voluntarily share with Us. This may include:
- Direct Identifiers such as Your first and last name, telephone number, fax number, postal address, or e-mail address;
- Personal Characteristics such as Your age, ethnicity, gender, citizenship, primary language or Your relationship to a disease (e.g., as a healthcare provider, a researcher, a diagnosed patient, a friend or relative of such a patient);
- Unique Identifiers such as a UCB product identifier/code (e.g., a lot number), Your medical insurance account number, Your clinical study identifier, or Your Social Insurance Number (for employment or tax reporting purposes);
- If you are a diagnosed patient, Your health Personal Information such as the date of Your medical diagnosis, information related to medication(s) taken or other treatment(s) such as Your experience with certain therapies including information regarding adverse events (seriousness, date and unique identification number), or any other information that may be legally required;
- If you are seeking employment, Your Professional Background and Work Experience; and
- Other Information such as the name of Your treating physician(s) or information related to Your health insurance coverage.
If you are a healthcare professional, We may also collect:
- Professional Information such as Your professional credentials (e.g., pharmacist), Your medical specialty, Your hospital or other affiliation(s), or Your educational background or expertise; and
- Professional Unique Identifiers.
Other categories of Personal Information may be collected from time to time and will be described wherever the request for personal information occurs (whether on a Website or offline).
You may choose not to provide Your personal information to UCB, but in general, some information about You is required in order for You to interact with UCB. Examples include: a Website registration process; a request to subscribe to a newsletter; asking a question to UCB; or to initiate a transactions on our Website. If you choose not to provide certain personal information to UCB it may not be possible to respond to your query or transaction.
Technical Information
We automatically collect some information about Your computer when You visit a Website, which we refer to as “technical information” in this Policy, which we use to help customize Your user experience. Technical information is generally used on an aggregate and anonymized basis and in a non-personally identifiable form, but if we can or do use your technical information to identify you, we treat such technical information as personal information in accordance with this Policy.
Usage details. We may automatically collect certain details of your access to and use of our Site, including traffic data, location data, logs and other communication data and resources that you interact with on or through our Sites, such as individual pages or products that you view and what websites or search terms referred you to the Sites.
Device information. We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, MAC address, operating system, browser type, mobile network information, and the device’s telephone number (where applicable).
The technologies we use for this automatic data collection may include:
Cookies. We may assign Your computer a “cookie” (a small, unique identifier text file). For example, whenever You sign into the Website, We record Your member ID and name on Your member account in a cookie file on Your computer. We also may record Your password in this cookie file, if You check “Remember me.” You can always choose not to receive a cookie file by enabling Your Web browser to refuse cookies or to prompt You before accepting a cookie. Please note that if You refuse to accept cookies from a Website, You may not be able to access some of the tools We offer.
Log files. Log files track actions occurring on our Sites, and collect data including your IP address, MAC address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
Web beacons. Small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) permit us, for example, to count users to have visited certain pages and other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Analytics information. Our Websites may use tools like Google Analytics to measure traffic to Our Site and how users interact with Our Site. Google Analytics employs cookies in order to facilitate an analysis of Your use of this site; the information generated by these cookies, such as time, place and frequency of Your visits to our Website, including Your IP address, is transmitted to Google’s location in the US and stored there.
Website users who do not want their data collected with Google Analytics can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript running on websites to prohibit sending information to Google Analytics.
To opt-out of Analytics for the web, visit https://tools.google.com/dlpage/gaoptout/ and install the add-on for Your browser. For more details, please see the relevant help resources for Your specific browser.
For more information, please review our Cookie Policy webpage.
Indirect information collection
We also may periodically obtain information about You from other sources (for example, insurance companies) and add it to Your account information, to which you consent under this Privacy Policy. One example of information We may receive from third parties is healthcare professional prescription histories or patterns, which We use to support Our strategic planning and operations.
Use of information
Except as otherwise stated, We may use Your personal information for the following general purposes:
- to provide You with the services You request, including any follow-up activities;
- to manage Your account;
- to respond to Your questions and comments;
- to measure interest in and improve the content of a Website;
- to customize this Website to Your preferences;
- to analyze and better understand Your needs, preferences, and interests;
- to send You information about products in which You may be interested;
- to solicit information from You, including through surveys;
- to resolve disputes or troubleshoot problems;
- to enforce our Terms of Use or Legal Notice; and
- for other purposes specified in this Privacy Policy or described to You at the point of collection.
For information regarding Your choices about such uses, please review the “Your choices” section of this Privacy Policy below. We will not sell Your name, address, e-mail address, or any other personal information to another party for their own marketing use.
Disclosure of information
We may disclose Your personal information to other UCB affiliates worldwide. In addition, We may disclose Your personal information to a third party for a business purpose. For example, We may disclose Your personal information:
- to third-party service providers We use to support our business (e.g., Internet service providers, hosting companies, financial institutions, and companies that provide business analytics, fulfillment services, technical support, and delivery services);
- to trusted third-party businesses with which We partner to offer You products and services;
- to pharmaceutical industry regulators such as Health Canada and the U.S. Food and Drug Administration, if required to do so by applicable laws;
- in accordance with applicable law, to a third party in connection with a business transaction, including (i) the purchase, sale or other disposition of UCB or part of Our business, (ii) a merger or amalgamation, (iii) a financing of Our business, (iv) the granting of a charge on Our assets, or (v) the lease or licensing of Our assets, including for the purposes of determining whether to proceed with such transaction;
- in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by applicable laws or government regulations;
- to protect and defend the rights of UCB, any Website or the users of any Website;
- under circumstances We believe reasonably necessary to protect the personal safety of users of UCB, Inc.’s products and services, this Website or the public; or
- as is otherwise described in this Privacy Policy or at the point of collection.
We also may share aggregate or anonymous information with third parties, including advertisers and investors. This information does not contain any Personal Information and is used to develop content and services We believe You will find of interest.
Protecting your personal information
UCB has adopted a number of recognized standards to protect the privacy of Your personal information, and We have provided a description and an example of these standards below. However, not every particular use or disclosure in every category will be listed.
We restrict and protect how Your personal information is used. We have guidelines which limit access only to those who have a reasonable need to use Your personal information. In addition, We limit how Your personal information is used to reasonable and legitimate business purposes. Finally, We may use Your personal information for business management and administration or to carry out Our legal responsibilities.
We restrict and protect how Your information is disclosed. As a global company with worldwide operations, We may share Your personal information with other UCB entities outside of Canada. As a result, your personal information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction. We limit these “affiliate disclosures” to circumstances where there is a legitimate business need, and any further use or disclosure of Your personal information is protected by Our global privacy policy and any applicable, country-specific privacy policy, law, or regulation.
For disclosures to third parties, it is Our standard practice to require those third parties keep Your personal information confidential and to use Your personal information only in a limited manner and in accordance with applicable data protection laws and regulations.
UCB will not sell or license Your personal information to third parties except in connection with the sale or transfer of a product line or division.
We use strong computer security protections. UCB has implemented technical, administrative and procedural safeguards in an effort to secure your personal information from unauthorized access, use or disclosure. Unfortunately, no such measure is ever 100 percent effective, so we do not guarantee that your personal information will be secure from theft, loss, or unauthorized access, use or disclosure, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard your personal information.
If You have reason to believe that Your personal information is no longer secure (for example, if You feel that the security of Your account has been compromised), please immediately notify Us using the contact information below.
We conduct privacy and security training and education programs. We provide appropriate training to staff who have permanent or regular access to personal information, who are involved in the collection of personal information, or in the development of tools used to collect, use or share personal information.
Your choices
You may choose:
- not to provide personal information, but that may result in Your inability to obtain certain services or use certain features of our Websites;
- to stop receiving commercial e-mails from Us in any such message We send or by sending an e-mail to the contact address at the bottom of this policy;
- to delete or decline cookies by changing Your browser settings. (Click “Help” in the toolbar of most browsers for instructions.) If You do so, some of the features and services of our Website may not function properly; or
- to review and update Your personal information by contacting Us at the link below and, if You have an online account on a Website, by logging into that account.
Your Privacy Rights
Depending on the jurisdiction in which you reside, You may have certain rights (including those described below) with respect to Your personal information that We collect and process. To exercise any of Your privacy rights, please contact Us as set out below under the “How to contact us” heading.
Updating your personal information. We want to make sure that the personal information that We have collected about You is accurate, complete and current. However, We will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which We collected the personal information. Since We generally rely on You to inform us if there have been any changes to the personal information that We have collected about You, please let us know if any of this information has changed.
Access to & correction of personal information. At Your request, You can have access to Your personal information in order to verify and update it, unless We are permitted or required under applicable laws to refuse Your access to such personal information.
Withdrawal of consent. Where You have provided Your consent to the collection, use and disclosure of your personal information, You may have the legal right to withdraw Your consent under certain circumstances. Please note that if You withdraw Your consent We may not be able to provide You with a particular product or service. We will explain the impact to You at the time to help you make Your decision.
Unsubscribe from marketing & promotional communications. If You are receiving our marketing and promotional electronic communications, You may unsubscribe at any time by clicking on the “unsubscribe” option in any electronic marketing communication (e.g. email) You receive or by contacting us as set out below under the “How to contact us” heading. Please note that if You unsubscribe from marketing communications, We may still send you transactional emails or emails about your use of our Sites.
Data Portability. Residents of Québec may request a copy of Your computerized personal information.
Links to other Websites
A UCB Website may contain links or references to other, non-UCB websites. Please be aware that We do not control other websites and that, in any case, this Privacy Policy does not apply to those websites. We encourage You to read the privacy policy of every website You visit.
International users
Unless otherwise stated, UCB’s Canadian Websites are intended for use only by Canadian residents. Any personal information You voluntarily share with UCB may be delivered to servers located in Canada or other countries. By using the UCB Canadian Websites, You consent to the transfer of any and all personal information that You provide to Us and to our use and disclosure of such personal information as outlined in this Privacy Policy.
How to contact us
If You have any questions, comments, or concerns about this Privacy Policy or the information practices of this Website, or wish to request an action described above, You can contact Us at dataprivacy@ucb.com or by regular mail to the attention of (i) the (global) data protection officer, Allée de la recherche 60, 1070 Anderlecht or (ii) the local UCB data protection officer at 2201 Bristol Circle, Suite 602, Oakville ON L6H 0J8.
1414-3051-3160