GLAXOSMITHKLINE CONSUMER HEALTHCARE (CANADA) WEBSITE PRIVACY POLICY Introduction: GlaxoSmithKline Consumer Healthcare Inc. ("GlaxoSmithKline" also referred to as "GSK", "us" or "we") respects the privacy of every individual who visits this Website and is committed to the protection of their personal information. We will only collect, use, and disclose your personal information in accordance with this Privacy Policy.
This Privacy Policy applies to GlaxoSmithKline and its directors, officers, employees, representatives, third party service providers and agents (the "GSK Group"). GlaxoSmithKline shall comply with Canadian federal and provincial privacy legislation as it is enacted, and applicable privacy legislation in jurisdictions where GSK carries on business. GlaxoSmithKline operations in jurisdictions with less stringent privacy laws are expected to make all reasonable efforts to meet the requirements of this Privacy Policy. However, nothing in this Privacy Policy or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against GSK or any of the GSK Group; nor will the existence of this Privacy Policy or its application impose any obligations or liability upon the GSK Group, or add to any such obligation or liability, that the GSK Group does not already otherwise have to any individual or person at law or otherwise.
This Privacy Policy is incorporated into and forms part of the Terms of Use, which outlines the terms and conditions you agree to when accessing and using the Website. By accessing and using the Website, you agree and consent to the collection, use and disclosure of your Personal Information as outlined in this Privacy Policy.
What Personal Information does GSK collect? "Personal information", as used in this Privacy Policy, means information about an identifiable individual, as defined in applicable privacy laws. Personal information may include your name, home address, home telephone number, home e-mail address, age, ethnic origin, income, blood type, medical records, credit records, preferences and opinions, but does not include the name, title or business address or telephone number of an employee of an organization.
Consumers: GSK may collect personal information about consumers when they voluntarily submit information to the Website, or otherwise communicate with us via the Internet (e.g., to enter a contest, request information or mailings, buy a product, or participate in a survey).
Children: GSK is committed to protecting the privacy of children and we do not knowingly solicit information from children under the age of 13, and instruct such children not to send us any information. If a child has already provided us with Personal Information, his or her parent or guardian may contact us for the purpose of deleting this information.
Service Providers: GSK may have third party service providers perform services relating to the development, operation and maintenance of the Website or relating to other services. These Service Providers may have access to your Personal Information, as is reasonably necessary, for the purpose of providing their services to GlaxoSmithKline.
When does GSK Collect Personal Information? We only collect personal information from you when you voluntarily provide it in order to access or use this Website (e.g., when you choose to participate in contests, promotions, quizzes, polls, questionnaires or surveys on the Website, or when you request information and/or use any interactive tools that may be available on this Website). If you refuse, are unwilling, or cannot accept the Terms of Use, which include this Privacy Policy, we may be unable to provide you with information or services from this Website.
Why does GSK Collect Personal Information? GSK and its agents, affiliates and service providers may collect, use or disclose Personal Information for one or more of the following purposes:
(a) to understand consumer needs and preferences, and to communicate with Website visitors and consumers;
(b) to conduct surveys, contests and promotions;
(c) to conduct research (e.g., quizzes, polls, questionnaires or surveys);
(d) to respond to your questions or requests for additional information;
(e) to provide you with information concerning products, services and/or promotions that you have specifically requested, or that GSK feels may be of interest to you;
(f) to personalize any interactive tools to better facilitate your use of the Website;
(g) to develop future e-newsletter topics for the Website;
(h) to improve the Website;
(i) to understand how we can improve our products and/or services;
(j) as permitted by, and to comply with, any laws or regulations; and
(k) for any other purpose to which an individual consents.
GlaxoSmithKline may also use aggregate information that does not contain Personal Information to track and monitor visitors' use of the Website. GlaxoSmithKline may also disclose aggregated information that does not include Personal Information to third parties.
To Whom Does GSK Disclose Personal Information? GlaxoSmithKline does not sell or otherwise transfer your personal information to third parties except as set forth in this Privacy Policy. GlaxoSmithKline will not disclose your Personal Information to any third party unless:
(a) such disclosure is otherwise revealed to you when you submit your information;
(b) such disclosure is required by law or by an order of a court of competent jurisdiction;
(c) such disclosure is necessary for Service Providers retained by GSK to perform functions on its behalf or to provide services to GSK, such as advertising, promotion and fulfillment services, market research, auditing, website administration, data processing, information technology and office services, provided such organization or individual does not collect, use or disclose the Personal Information for any purpose other than to perform such functions or provide services to GSK;
(d) the rights or property of GSK, its affiliates, Service Providers, or users of the Website are in jeopardy;
(e) the safety of users of the Website or the general public are in jeopardy;
(f) Personal Information is included in a transaction for the sale or securitization of some or all of our assets.
How does GSK Collect, Use and Disclose Personal Information? GSK collects, uses and discloses Personal Information in accordance with the following ten privacy principles, which form the basis of this Privacy Policy.
Accountability GSK is responsible for Personal Information under its control and has designated Privacy Officers to be accountable for GSK's compliance with this Privacy Policy and applicable laws.
Identifying Purposes for Collection of Personal Information GSK identifies the purposes for which Personal Information is collected at or before the time the Personal Information is collected. Some of the identified purposes for which GSK currently collects, uses or discloses Personal Information are described above.
Obtaining Consent for Collection, Use or Disclosure of Personal Information The knowledge and consent of an individual are required for the collection, use, or disclosure of his or her Personal Information, except as permitted by law. In obtaining consent, GSK uses reasonable efforts to ensure that an individual is advised of the identified purposes for which Personal Information will be used or disclosed. In determining the appropriate form of consent, GSK takes into account the sensitivity of the Personal Information and the reasonable expectations of a reasonable person. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. At that time, GSK will advise the individual of the implications of such withdrawal.
Limiting Collection of Personal Information GSK limits the collection of Personal Information, both the amount and the type of information, to that which is necessary for the purposes identified by GSK. GSK collects Personal Information by fair and lawful means, and not by misleading or deceiving individuals about the purpose for which information is being collected.
Limiting Use, Disclosure, and Retention of Personal Information GSK does not use or disclose Personal Information for purposes other than the identified purposes for which it is collected, except with the consent of the individual or as required or permitted by law. GSK retains Personal Information only as long as is necessary to fulfill the identified purposes.
Accuracy of Personal Information Personal Information held by GSK is as accurate, complete and up-to-date as possible for the purposes for which it is to be used. As far as possible, Personal Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate Personal Information may be used to make a decision about an individual. GSK does not routinely update Personal Information, unless such process is necessary to fulfill the identified purposes. We rely on individuals to inform us of any changes to their Personal Information. To update your Personal Information, please contact us directly at privacy.1.officer@gsk.com.
Security Safeguards GSK protects Personal Information by security safeguards appropriate to the sensitivity of the information. GSK uses reasonable efforts and security measures to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction.
Openness Concerning Policies and Practices GSK makes this Privacy Policy readily available to individuals in order to provide specific information about its policies and practices relating to the management of personal information. This Privacy Policy is available on the GSK website at http://services3.pvt.ciberpgh.com/CHUSCanada30/legal/legal.aspx?iso=en and upon request to GSK via the contact information provided below.
Individual Access to Personal Information Upon written request from an individual, GSK will inform the individual of the existence, use, and disclosure of his or her Personal Information and, subject to certain exceptions provided by law, will give the individual a reasonable opportunity to review the Personal Information collected by GSK. GSK will make every reasonable effort to provide Personal Information in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. If access is denied [NTD: if applicable], GSK will inform the requesting individual in writing.
Challenging Compliance Consumers may address a challenge concerning compliance with this Privacy Policy to GSK's Privacy Officer. All contact information is provided below.
Privacy and GSK's Websites: Your personal information is stored on secure servers maintained by GlaxoSmithKline or by a third party on GSK's behalf as outlined below. Information collected on the Website, including Personal Information, may be stored on secure servers located outside of Canada.
GlaxoSmithKline is careful to ensure that the Personal Information you voluntarily provide to the Website is as secure as possible; however, you must be aware that transmissions over the Internet cannot be guaranteed to be completely secure. GlaxoSmithKline, its affiliates and any directors, officers, employees, agents, contractors, subcontractors or agents of the foregoing do not represent, warrant or guarantee that Personal Information will be protected against misuse, loss or modification, nor do such parties accept liability for the security of a user's Personal Information submitted on or in connection with the Website.
IP Protocol (IP) Addresses When you access the Internet using your computer, your Internet service provider assigns you an IP Address. Generally, every time you connect to the Internet, your IP Address changes. In some circumstances (e.g., with some broadband connections) your IP Address may not change in which case, it can be associated with your particular computer. Examples of the type of information that can be collected using your IP Address include your type of Internet Browser and the type of computer operating system you are using. GSK, or its authorized agents, use your IP Address to collect and report aggregate information on how the Website is being used and ways in which the Website can be improved.
Web Log Information Web log information is non-personal information that is collected by the computer that hosts the Website (the "Website Server") when you visit the Website, including, but not limited to, the date and time you visited the Website, the type of Internet Browser you are using and the type of computer operating system you are using. Web log information may be collected and used by GlaxoSmithKline or its authorized agents in aggregate to assess how the Website is being used and how to improve the Website.
Cookies This Website uses a technology called "cookies". A cookie is a token that a server gives to your browser when you access a website on the Internet. Cookies are capable of storing many types of data. Cookies help provide additional functionality to the Website and help us analyze the Website usage more accurately. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to the Website. In all cases in which cookies are used, we will not collect Personal Information without your explicit permission. With most Internet Browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your Internet Browser's instructions or help screen to learn more about these functions.
You should be aware that operators of third party websites linked to the Website may also collect your Personal Information through the use of "cookies". GlaxoSmithKline, its affiliates and any directors, officers, employees, agents, contractors, subcontractors or agents of the foregoing shall not be responsible for how such operators collect, use or disclose your personal information. You need to contact these operators directly for information on their data collection and distribution policies. Your linking to a third party website or webpage is entirely at your own risk and subject to the terms and conditions of such websites or webpages.
Contacting GlaxoSmithKline By E-mail Any communication, comments, ideas, concepts, know-how, techniques, material or other information (collectively, the "Communication") that you voluntarily post or transmit to GSK by e-mail is, and will be treated as, non-confidential and non-proprietary. By transmitting any Communication to GSK by e-mail, you grant to GSK and all of its affiliates, an unrestricted, irrevocable license to use, reproduce, display, modify, transmit, distribute, publish, broadcast or post your Communication for any purpose. However, we will not release your name in connection with such Communication unless:
(a) you grant us permission to do so;
(b) we first notify you that the Communication you submit to a particular part of the Website will be published or otherwise used with your name on it; or
(c) we are required to do so by law.
Links Our websites may contain links to other websites which are provided to you as a convenience only. You are advised that other third party websites may have different privacy practices than GSK, and GSK has no responsibility for such third party websites.
Changes to this Privacy Policy: GSK reserves the right, at its sole discretion, to modify this Privacy Policy at any time. Changes to this Privacy Policy will be posted on this page of the Website. Your continued access or use of the Website constitutes your acceptance of the Privacy Policy as revised. It is your responsibility to review the Privacy Policy frequently.
Making Changes to your Personal Information: If we hold Personal Information about you, you are able to access, change and update your Personal Information at any time. Requests for access to your Personal Information (please include your contact information) can be made in writing to:
Privacy Officer
GlaxoSmithKline Consumer Healthcare
2030 Bristol Circle
Oakville, Ontario L6H 5V2
You may delete, edit or modify any information you have submitted using any of the interactive tools available on the Website at any time. If you do not wish to receive further e-mail or other mail from us, please e-mail us at:
privacy.1.officer@gsk.com Questions about your Personal Information collected: All questions or concerns regarding our use of your Personal Information should be directed, in writing, to:
Privacy Officer
GlaxoSmithKline Consumer Healthcare
2030 Bristol Circle
Oakville, Ontario L6H 5V2
Copyright © 2008 GlaxoSmithKline Consumer Healthcare Inc. All rights reserved.