This website (“Website”) is operated by AFT Pharmaceuticals (CAN) Ltd and its affiliated entities (referred to on the Website as “AFT”, “we”, “our” or “us”). We value and respect your privacy. This Privacy Policy (“Policy”) describes the personal information we may collect from you, the purposes for which we collect it, how we process it and when we may share it with third parties. This Policy also describes the choices you can make about how we collect, use and disclose your information.
This Policy applies to your use of the www.aftpharm.com/ca-en/ regardless of whether you access or use it via a computer, mobile device or another platform. This Policy also applies to personal information we obtain through email communications, our online channels (including other websites, product catalogs, mobile applications and social media websites that reference this Policy) and to personal information you provide us offline (e.g., during in-person events) (all such online channels, Website, product catalogs, mobile applications, social media sites, and offline interactions shall collectively be referred to herein as the “Services”).
1 – Who is responsible for the Processing of Your Personal Data?
The AFT entity responsible for the processing of your personal data will depend on how you interact with AFT’s website and where you are located in the world. The relevant AFT entity referred to as “AFT”, “our”, “we” or “us” in this privacy policy.
2 – What Personal Data do we Collect and When?
The type of personal data that we will collect from you, and you voluntarily provide to us on this website may include some or all of the following depending on the type of user you are:
| Storage Type | What we Store |
|---|---|
| User-Generated Content/Data | Name, Email Address, Free Format Text (Subject and Message for “Contact us” submission) |
| Website Usage Data | IP Address, Browser Type and Version, Operating System, Device Information (e.g., device type, screen resolution), Date and Time of Website Visits, Pages Visited on the Website, Clickstream Data (User’s navigational path) |
| Cookies and Tracking Data | Cookies (e.g., session cookies, persistent cookies), User Tracking Information (for analytics and personalization) |
| Purchase History | A description of the items purchased online or offline, the date of the purchase, amount paid. The purchase history includes your history of returns made after a purchase. |
Not all information we collect identifies you or can be attributed as being identifiably about you when taken on its own. Similarly, we may aggregate your information with other information in a way that it is not attributable as being identifiably about you (including by aggregating it into groups or categories). This Policy does not apply to restrict our collection, use or disclosure of such non-identifiable information. However, this same information may be considered personal information if we combine it with other information (such as identifiers like your name or address) in a way that makes it attributable as being identifiably about you. This Policy will apply to your information when it is combined in this identifiable way.
If you provide us with another person’s personal information, you represent that you have obtained all necessary consents from that person to authorize us to collect, use and disclose that personal information for the purposes set out in the Policy.
3 – Why and How We Use Your Personal Data
We may use your personal information for the purposes for which it was collected, in accordance with our Policy, for other purposes authorized by law or with your consent.
We may use the information collected in the following ways:
A – When you use our website “Contact Us” submission form
When you make an enquiry on our website using the “Contact Us” section, we will use your name, email address, phone number, and any other information provided to contact you about, and manage your enquiry. If your enquiry relates to an adverse reaction to any product, we will hold and manage your information in order to meet their legal requirements and may pass information to any relevant Regulators. Wherever possible, and legally permitted, we will take steps to anonymize any information before it is transferred.
B – To Operate, Improve and Maintain our Business, Products, and Services
We use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits, and other internal functions. We may use personal data about how you use our website to enhance your user experience and to help us diagnose technical and service problems and administer our platform. Lastly, we may use your personal information to support our marketing and advertising efforts (e.g., to recommend products that you may like).
C – To Protect Our or Others’ Rights, Property, or Safety
We may also use personal data about how you use our website and platform, to prevent, detect, or investigate fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests, or applicable law.
4 – Sharing of Your Personal Data
Except as set out below, we do not disclose or sell the personal information you have provided us to third parties.
We may transfer your personal information to our service providers who help us achieve the purposes for which your personal information was collected, including server hosting providers who help us store your personal information. Moreover, we may also disclose your personal information:
- to comply with our obligations under any law or regulation, investigation by a government authority, subpoena or court order, or other administrative or governmental authority;
- to a third party (e.g., co-branding partners or AFT affiliates) where you express interest in, or choose to purchase or participate in, a promotion, program, activity, service, or product offered by the third party. However, if you do not want your personal information to be shared in this way, you may opt not to express interest in, or not to purchase or participate in, such promotions, programs, activities, services, or products;
- to a law enforcement agency or government agency in connection with an investigation of fraud, real or potential, a violation of a law, regulation or conditions of use of the Website, or for the protection of rights, ownership or security of AFT, our customers/users or partners;
- to an acquiring entity in connection with the completion or proposal of a business transaction (including its achievement/implementation, liquidation, foreclosure or repossession), concession, merger, business combination or any other type of acquisition, liquidation, transfer, transfer contract or financing of AFT, in whole or in part, or of any property, stock, asset, share or business of AFT; and
- If you choose to share personal information publicly, with other users of the Website, or with other sites (such as social media sites), we may facilitate this sharing. We do not control these third parties that you might choose to share your personal information with or how they use your personal information, and we are not responsible for their privacy practices. You should review the privacy policies of any third party before you decide to share your personal information with them and always exercise caution when publicly sharing your personal information.
We require service providers to safeguard the security of your personal information and to treat it in accordance with the law. We do not allow our service providers to use your personal information for their own purposes and we only allow them to process your personal information for specific purposes and in accordance with our guidelines.
5 – Cookies
We use cookies, which are small text files stored on your device. Using cookies is a way for us to make sure that our website is continuously improved, meets your needs and can be used as a tool to optimize our marketing strategy. For us to do this, we place functional cookies to make the website function as well as marketing cookies which help us target the right people and show them advertisements. Some of these cookies track your use of our website and visits to other websites and allow us to show you advertisements when you browse other websites.
Please view our Cookie Policy (www.aftpharm.com/ca-en/cookie-policy/) for more information on our use of cookies.
6 – Rights under Data Protection Law
Depending on your place of residence, and subject to certain exceptions permitted by law, you may have the following rights with respect to the personal information we hold about you:
A – The Right to be Informed about our Collection and Use of Personal Data
You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal data protection policies and through our external website privacy notice. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.
B – Right to Access Your Personal Information
You may have the right to access the personal information we hold about you and to receive a general account of our use of that personal information. Upon receipt of a written request from you, we will provide you with a copy of your personal information, although under certain limited circumstances, we may not be able to make all relevant personal information available to you, such as when the personal information also affects another natural person. In such circumstances, we will inform you, upon request, of the reasons for this refusal. We will endeavor to process all requests for access to personal information in a timely manner. Additionally, in certain cases, there may be a cost associated with fulfilling your request, in which case we will inform you of the approximate cost and wait for your approval before you respond to your request. If you would like to exercise this right, please contact us as set out below.
C – Right to Correction Your Personal Information
If any of the personal information we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct it.
If you would like to exercise this right, please contact us as set out below.
D – Right to Stop or Limit Our Processing of Your Data
Under applicable law, subject to legal or contractual restrictions and reasonable notice, you may have the right to object to us processing your personal information for particular purposes, to withdraw your consent from certain processing activities involving your personal information, or to have its processing restricted in certain circumstances.
You can ask us to restrict processing your data, for example where:
- you’re contesting the accuracy of your personal data.
- we no longer need to process your personal data, but you want us to keep it for use in legal claims.
- you’ve objected to the processing by asking us to stop using your data, but you’re waiting for us to tell you if we have overriding grounds which mean we’re allowed to keep on using it.
If you would like to exercise this right, please contact us as set out below.
E – Right to Erasure
You may have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. Where the right doesn’t apply, we’ll let you know why we can’t action your request.
This right may be applied where:
- personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
- the processing was based on your consent which you withdraw (and there are no other legal grounds for processing that data).
- you exercise your right to object and there are no overriding legitimate grounds for the processing.
- there is no lawful reason to retain personal data or if the personal data must be erased to comply with a legal obligation.
If you would like to exercise this right, please contact us as set out below.
F – Right to Portability
The right to portability may in some circumstances give you the right to receive personal data you have provided to a controller in a structured, commonly used, and machine-readable format depending on where you live.
If you would like to exercise this right, please contact us as set out below.
G – Rights in Relation to Automated Decision Making and Profiling
Depending on your place of residence, you may have rights around automated decision-making and profiling. Automated decision-making generally means a decision made solely by automated means, using personal information and without any human involvement. Profiling means the processing of your personal information to evaluate certain things about you. You have the right to information about these kinds of processing, and depending on your place of residence, you may have the right to ask for human intervention or to challenge an automated decision.
If you would like to exercise this right, please contact us as set out below.
7 – Third-Party Processors and Service Providers
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
| Service | Description |
|---|---|
| Security Vendors | These trusted experts employ advanced cybersecurity measures, such as intrusion detection, threat monitoring, and malware scanning, to protect your personal data from unauthorized access and cyber threats. |
| Customer Support Providers | We work with dedicated customer support providers. They assist in addressing your queries, resolving issues by securely managing and accessing relevant customer data. |
| Content Delivery Networks (CDNs) | To optimize the speed and reliability of our online services, we rely on Content Delivery Networks (CDNs). CDNs efficiently deliver web content to you by strategically distributing it across global servers. Your data is cached and served from the nearest server, reducing latency, and enhancing your overall experience. |
| Content Management Systems | To assist us in the creation, management, and design of our website. |
| Analytics and Advertising | To improve our products and provide you with relevant content and advertisements, we collaborate with analytics and advertising partners. They analyze user behavior, preferences, and demographics to personalize your experience and deliver targeted ads. |
| Hosting Services | Providing the facilities needed to create and maintain our website, as well as make it accessible through the internet. |
| Third Party | Service Provided | Description of Service |
|---|---|---|
| Podcom | IT infrastructure and development services | Podcom offers managed IT support and development services for AFT Group. |
| Fastly | Content Delivery Network and Web protection services | Fastly offers web efficiency and protection services for our platform. Fastly – Privacy Policy |
| P29 | Website Management and Administration | P29 offer website design and management services for our product. Platform29 – Privacy Policy |
| WordPress | Content Management | WordPress offers web content management systems. WordPress – Privacy Policy |
8 – How Long We Keep Your Information
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Where the same record has to be kept for more than one purpose and there is a different retention period for each of those purposes, the record is kept for the longer period.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9 – Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Platforms, systems, and facilities in which personal data are processed are protected by secure network architectures that contain firewalls and intrusion detection devices.
In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They are required to only process your personal data on our instructions, and they are subject to a duty of confidentiality.
10 – Where We Store Your Personal Information and International Data Transfers
By providing us with personal information, you acknowledge and agree that such personal information may be transferred to other jurisdictions for processing and storage, including in servers located across Canada, in New Zealand, and in the United States, where laws regarding the protection of personal information may be less stringent than the laws in your jurisdiction. Further, such personal information may be accessible to law enforcement, national security authorities, and the courts of such jurisdictions.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of your jurisdiction of residence.
11 – Contact Us
If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, the way your personal information is processed, please contact us by one of the following means:
AFT Pharmaceuticals (CAN) Ltd, FAO Data Protection Officer (DPO)
PO Box 33-203 Takapuna, Auckland, New Zealand 0740
Email: customer.service@aftpharm.com
Phone: (+64) 0800 423 874
You can contact the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner’s office at any time about the way we use your information. However, we hope that you would consider raising any issue or question you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.