politique de confidentialité / privacy policy

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politique de confidentialité / privacy policy
Domain Therapeutics NA Inc.

Last updated: June 14 2023

Domain Therapeutics NA Inc. (“DTNA”, “us”, “we”, “our”) takes your privacy and the protection of your personal information seriously. This Privacy Policy (the “Policy”) describes our data protection practices, the types of personal information we may receive or collect from you and of how we use, disclose, store and secure it. By doing so, you will be able to make wise and informed choices.

This Policy applies to our website available at https://www.domaintherapeutics.ca/ (“Website”). However, we wish to draw your attention to the fact that the rights and obligations described in this Policy do not cover third-party websites that may be linked to or mentioned on our Website. These third-party websites have their own privacy policies and we encourage you to read them carefully.

1. PERSONAL INFORMATION

For the purposes of this Policy, “Personal Information” means any information about an individual that identifies the individual or that, individually or in combination with other information, identifies the individual. In general, Personal Information does not include business contact information, such as your name, title and position, as well as work address, e-mail address and telephone number.

2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

With a legal basis such as your consent

Generally, we will obtain the Personal Information that we need directly from you with your consent, subject to exceptions as provided by applicable laws. For example, DTNA may need to proceed without your consent where, for reasons of fraud detection or prevention, seeking your consent would defeat the purpose. To the extent permitted by applicable laws, DTNA may also rely on other legal grounds, for example, where processing is necessary to comply with legal obligations to which it is subject.

You provide us with Personal Information directly, for example when you use our Website or when you communicate with us.

Refusal of collection and withdrawl of your consent

You have the right, if you so choose, to refuse the collection, use and disclosure of your Personal Information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent to the use of your Personal Information in our possession by contacting us. You should be aware, however, that if you choose not to provide us with your Personal Information, this may prevent you, for example, from using the Website, and accessing our services, as this information is essential to the provision of the requested services.

We would also like to inform you that anonymized information, which does not allow us to know who you are, might be kept even if you withdraw your consent.

Use for secondary purposes

Depending on the circumstances, DTNA may also ask for your consent to use your Personal Information for secondary purposes, such as market research or database purposes. Your consent for secondary use may be withdrawn at any time by contacting us, without affecting the provision of our services to you.

3. WHAT PERSONAL INFORMATION DO WE COLLECT?

In the course of our business and service delivery, Personal Information collected may include, but is not limited to:
• Your contact information, such as a name, email address or telephone number in order to identify and correspond with you;
• Your login information such as your email address;
• Any other Personal Information you have provided to us.

DTNA also collects information relating to the use of its Website including technical information about your visits, the conversion rate, the average length of a visit, the action carried out on the Website, the type of device used, the web browser used during the visit, the IP address, the origin of visitors, or any other information collected through cookies or similar tools. For more information in this regard, we invite you to read the section, “Cookies and other similar tools”.

4. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

For limited and specific purposes

Personal Information collected by DTNA may be used for the following purposes:
• To establish and manage our relationship with you;
• To provide and maintain the services requested, namely the access to the Website;
• For research and development, statistical purposes and to improve the use of our Website and your customer experience;
• Respond to your requests for information;
• Respond to your support requests;
• To enable business development and marketing, including informing our current and future customers about our new offerings, with the prior consent of the individual concerned;
• As permitted or required by any applicable legal or regulatory obligation or provision;
• Any other purposes that we identify from time to time to which you have consented, and that are authorized by law.

For secondary purposes

DTNA may also aggregate and anonymize Personal Information you have provided in order to create statistical data that DTNA may use to improve the Website and train machine learning algorithms. DTNA may also share this information with its partners. Such statistical data does not include Personal Information.

5. COOKIES AND OTHER SIMILAR TOOLS

We may use various tools to improve your experience on our Website, to better understand our customers’ behaviour, and in connection with our marketing strategies. The following section is intended to give you more information about how we use these tools.

Cookies and web beacons

DTNA may use cookies and web beacons. In general cookies are small data files that are commonly stored on your device when you use websites and online services. On the other hand, web beacons are tiny images that we may place on our web pages or emails. They can be used, for example, to obtain anonymously the number of times a particular page has been visited by a user or whether an email has been read. As the name implies, web beacons are invisible in any part of our Website. Unlike cookies, web beacons are not placed on your computer. For the purpose of this Policy, cookies and web beacons are collectively referred to as “cookies”.

Cookies that we use

DTNA may use different types of cookies. As set forth below, some cookies are strictly necessary to the proper functioning of the Website while others are used with your prior consent for functional, performance or advertising purposes.

• Necessary cookies: We use strictly necessary cookies to enable the proper functioning of our Website, our security measures and those of third parties. Without these cookies, the services you have requested cannot be provided.

• Functionality cookies (also known as “preference cookies”): These cookies are not essential to the provision of our services. They help personalize and enhance the user experience. For example, if you have consented to their use, such cookies will store your communication and language preferences.

• Analytic cookies: These cookies are not essential to the provision of our services. If you have consented to their use, we use performance cookies to understand how you interact with our Website. Our partners may also use this type of cookie to analyze your use of our Website and provide us with information about it. These cookies are for statistical purposes only. For more information on our use of cookies, see the “Use of Analytics Tools” section.

Use of analytics tools

If you have consented to their use, DTNA uses analytics tools to analyze the Website traffic and usage. Among others, we use the Google Analytics tool offered by Google LLC (“Google”), to collect information about how you navigate our Website. You can get more information about Google Analytics here.

Deactivation of cookies to which you have consented

Except for strictly necessary cookies, we will only place cookies on your device if you consent to it, and such cookies will be kept for a maximum period of twelve (12) months from when they are placed on your device. At the end of this period, your consent will be required again.

You can also manage your cookie settings at any time by following the instructions below. However, if you choose to decline cookies, some pages or sections of our Website may not display properly or some features may not be available.

• Set your preferences on your browser. You can manage your cookie settings by changing the settings on your browser or device. For details on how to set up your browser, please see the help centre for Chrome, Safari, Firefox, Internet Explorer, Edge or Opera.

• Deactivate Analytics. You can deactivate Google Analytics by installing this add-on.

6. HOW DO WE SHARE AND DISCLOSE YOUR PERSONAL INFORMATION?

In the course of our business, we may need to disclose and share your Personal Information with various stakeholders as described below:

• Our Employees: In the course of their work, our employees may need to access your Personal Information, for example, when you contact us to request support. Their access is limited to what is necessary to perform their duties.

• Agents and Service Providers: From time to time, we may need to share your Personal Information with agents or service providers to help us make the features of our Website available (e.g., maintenance, analysis, legal requirements, fraud detection, hosting, marketing and development). As part of these activities, DTNA’s service providers may have access to and use your Personal Information for a limited time. When DTNA engages third parties to process any Personal Information, DTNA implements reasonable contractual and technical safeguards to ensure that such third parties keep all Personal Information they process strictly confidential. Please note that these third parties may be located in locations other than your current location, in which case appropriate measures are taken by DTNA. For more information on the transfer of Personal Information, see “Do we transfer your personal information outside of Québec?” section.

• When required by law, to enforce compliance or to protect the property or safety of our rights or those of others: For example, we may disclose Personal Information to legal or regulatory authorities in the event that we suspect money laundering, insider trading, manipulative or deceptive business practices or other criminal activities, to detect and prevent fraud, or to comply with legal or regulatory requirements of governmental authorities, regulatory bodies or other self-regulatory organizations. We may also need to disclose Personal Information to comply with a legal obligation (e.g., court order) or to protect our assets (e.g., to collect overdue accounts).

• Business Transfers: As part of our business development, we may sell or buy businesses or services. In such transactions, Personal Information generally becomes part of the transferred business assets, but remains subject to the promises made in any pre-existing privacy policy (unless, of course, the individual consents otherwise).

7. DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE OF QUEBEC?

The Personal Information that we collect is stored in secure systems hosted on servers that may be located outside your province, territory or country of residence. We may also retain the services of agents and service providers who may be located outside of Quebec.However, we strive to protect the Personal Information in our custody, including Personal Information entrusted to an agent or service provider, whether located in Canada or other jurisdictions or countries. In particular, we endeavour to limit their access to Personal Information to that which is necessary to perform the tasks they are assigned. Please be aware that we proceed with privacy impact assessments and also strive to have contractual agreements in place with these agents and service providers to ensure the confidentiality and security of your Personal Information. This may include implementing robust and effective security measures. If you have any additional questions on this subject, you can contact us.

8. HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

Personal Information will be retained only as long as necessary for the fulfillment of those purposes or as required by law for retention periods. As such, the length of time we retain your Personal Information will vary depending on the purpose for which it is to be used. At the end of such period, we strive to destroy or anonymize this information. If you would like more information on this subject, we invite you to contact us.

Any user may request that his or her account be deleted by sending a request by email.

9. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

With necessary and appropriate measures

We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the Personal Information in our possession. In doing so, we follow generally accepted industry standards. The Personal Information in our possession is therefore only accessible to those persons who have the authority to access it and who consult it only when necessary for the performance of their duties.

Appropriate physical, technical and administrative safeguards and security measures have been put in place and are maintained to minimize the risk of incidents. Example of such measures includeprivacy impact assessments, contractual obligations and restricted access to the physical office and to personal information. If you believe that your Personal Information has been compromised, we invite you to contact us.

Children’s Privacy

The Website is only available and designed for persons 14 years of age or older. If you believe that Personal Information has been collected from children under the age of 14, or if you are a parent or legal guardian and believe that your child under the age of 14 has provided us with Personal Information, you may contact us as set forth in the “Questions, comments, complaints”. section.

10. WHAT ARE YOUR RIGHTS?

Depending on applicable laws, you might have the right to obtain access to, or correct the Personal Information collected by us, as well as the right to portability and de-indexation of your personal information, the right to request deletion of your Personal information and the right to withdraw your consent (if any).

You also have the right to make a complaint to the appropriate authority at any time if you believe that DTNA is not processing your personal information in accordance with this Policy or applicable law.
To exercise any of these rights, we invite you to contact us by writing to the address available in the section, “Questions, comments, complaints”. For more information about exercising your rights in Québec, you may also consult the following website Commission d’accès à l’information du Québec.

11. CHANGES AND UPDATES TO THE POLICY

DTNA may, at its discretion, update, revise, modify or supplement this Policy from time to time. If material changes are made to the Policy, you will be notified when you log in and/or we will send you a link to the new version of the Policy. The Policy and any related agreements, if any, will be posted on our Website. DTNA requests that its users review the revised Policy before continuing to use its Website.

12. QUESTIONS, COMMENTS, COMPLAINTS

DTNA has established procedures for receiving complaints and inquiries about its Personal Information management policies and practices, including the retention and destruction of personal information, the roles and responsibilities of DTNA employees and the handling of privacy complaints. We will inform individuals who make inquiries or lodge complaints of the existence of the relevant procedures. DTNA will investigate all complaints. If a complaint is found to be justified, we will take appropriate action including, if necessary, amending our policies and practices. Please feel free to contact us with any questions, inquiries, comments or complaints about your Personal Information. To do so, we invite you to contact us at the following address:

Privacy Officer

Mr Guy Le Houillier, General Manager
Address : 7171 Frederick-Banting Street, Montréal (Québec) H4S1Z9 Canada
Phone Number: +1 514 375 2320
Email address : contactdtna@domaintherapeutics.com