Last Revised August 11, 2022
At Reunion Neuroscience Inc. (“Reunion”), we are committed to protecting your privacy and safeguarding your personal information. The purpose of this Privacy Statement is to inform you about the types of Personal Information Reunion (as follows, “we” or “us”) collects, uses and discloses in connection with the programs offered by Reunion (the “Reunion Programs”). It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.
We are committed to your privacy, and to complying with the laws and regulations under applicable privacy laws in Canada, and specifically the Personal Information Protection and Electronic Documents Act (Canada) and the regulations thereunder. From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the“last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently.
The following topics will be covered in this Privacy Statement:
1. What is Personal Information?
2. How do we collect your Personal Information?
3. Where do we store your Personal Information?
4. How do we use your Personal Information?
5. To whom do we provide your Personal Information?
6. When and how do we obtain your consent?
7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
8. How long will we utilize, disclose or retain your Personal Information?
9. How can your review your Personal Information that we have collected, utilized or disclosed?
10. How do you know that the Personal Information we have on you is accurate?
11. What if the Personal Information we have on you is inaccurate?
12. How fast will we respond to your written requests?
13. Are there any costs to you for requesting information about your Personal Information or our privacy practices?
14. How do we know that it is really you requesting your Personal Information?
15. What safeguards have we implemented to protect your Personal Information?
16. What information is collected by your websites and through cookies?
17. How do you contact us regarding access to your Personal Information or our privacy practices
1. What is Personal Information?
“Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, contact information, information that relates to your physical or mental health, including information that consists of the health history of your family, information related to your health, and Reunion usernames and passwords. Personal Information, however, does not include your name, business title or business address and business telephone number in your capacity as an employee of an organization.
2. How do we collect your Personal Information?
We will always collect your Personal Information by fair and lawful means. We may collect Personal Information from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent, or as otherwise required or permitted by law.
3. Where do we store your Personal Information?
We will keep the Personal Information that we collect either at the Reunion offices or our service provider’s data centres in Canada and the United States.
4. How do we use your Personal Information?
We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):
- to facilitate and administer your access to the Reunion Programs;
- to facilitate communications with employees and third-party service providers with whom we have a contractual relationship such as, contract research organizations or search firms;
- to advise you about new programs and products that may be of interest to you;
- to respond to your inquiries, complaints or requests;
- to collect opinions and comments in regard to Reunion’s operations;
- to investigate and defend legal claims;
- such purposes for which Reunion may obtain consent from time to time; and
- such other uses as may be permitted or required by applicable law.
5. To whom do we provide your Personal Information?
Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all of the business of Reunion (in which case the use of your personal information by the new entity would continue to be limited by applicable law), or as otherwise permitted or required by law. In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and maybe subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
6.When and how do we obtain your consent?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances. In limited circumstances, we may rely on a third party to obtain your consent to the sharing of your personal information with us. You may withdraw your consent by providing us notice.
7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
We ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Statement and our privacy practices.
8. How long will we use, disclose or retain your Personal Information?
We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.
9. How can you review your Personal Information that we have collected, used or disclosed?
If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by law.We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.
10. How do you know that the Personal Information we have on you is accurate?
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you,from time to time, to supply us with written updates to your Personal Information, when required.
11. What if the Personal Information we have on you is inaccurate?
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
12. How fast will we respond to your written requests?
We will attempt to respond to each of your written requests not later than 30 days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of Canada and/or the Information and Privacy Commissioner of Ontario in respect of this time limit.
13. Are there any costs to you for requesting information about your Personal Information or our privacy practices?
We will not charge any costs for you to access your Personal Information in our records or to access our privacy practices without first providing you with an estimate of the approximate costs, if any.
14. How do we know that it is really you requesting your Personal Information?
We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
15. What safeguards have we implemented to protect your Personal Information?
We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification.The only employees, contractors and third-party service providers granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
16. What information is collected by your websites and through cookies?
When you visit any of our websites, we collect information from you automatically. This includes the URL of the site you came from, your browser, your Internet Protocol (IP) address, date/time of access,data transferred, pages visited, amount of time on the websites, transactions conducted, and other “clickstream” data. This information is used to assist us in our marketing efforts, help diagnose technical problems, and to improve our websites.
We may also collect “de-identified data” from website visitors, in other words data that does not identify an individual, to: monitor system usage, server and software performance, to improve system design, to create benchmarks and to conduct trending analyses, and perform statistical analyses and generate data related to how you use our website.
We use functional cookies on our website to deliver the desired functionality and user experience and analytics cookies to collect and analyze aggregate visitor behaviour. Cookies help us better understand how our websites are used and to improve them, as well as provide visitors the benefit of not having to re-enter the same data over and over again. You can disable cookies and still obtain access to most of our websites. Information about website visitors may be collated and analyzed by third party services likeGoogle Analytics.
17. How do you contact us regarding access to your Personal Information or our privacy practices?
All comments, questions, concerns or complaints regarding your Personal Information, this Privacy Statement or our privacy practices,should be forwarded to our Privacy Office at the following address:
Reunion Neuroscience Inc.
257 S 25th St
Philadelphia, PA 19103
Attn: Privacy Office
legal@reunionneuro.com
When contacting Reunion regarding any issue, please do not include any Personal Information (other than your contact information) or health information in the subject line or in the content of your message. Note that email is not a secure method for transmitting information.