Last updated: March 2025
INTRODUCTION
This Privacy Notice describes the privacy practices of Therakos (Canada) Company and our affiliates (collectively, “Therakos,” “us,” or “we”). We take your privacy seriously, and we want you to know how we collect, use, disclose, and otherwise process personal information in Canada. This Notice also explains the rights and choices available to you with respect to your personal information.
This Privacy Notice applies to you if you interact with us, including but not limited to:
- If you are a health care professional that registers with therakoshcp.ca or other Therakos websites (“Therakos Websites”) or otherwise interacts with our offerings for health care professionals;
- If you visit, use, or register with the Therakos Websites; and
- If you are a patient undergoing a Therakos treatment.
Therakos may provide additional privacy notices to individuals at the time we collect their data. For example, we provide a specific privacy notice to clinical trial participants that describes our privacy practices in connection with conducting clinical trials. This type of an “in-time” notice will govern how we may process the information you provide at that time.
This Privacy Notice does not apply to data that is not personal information, such as business information or anonymized, aggregated, or de-identified information like statistics.
INFORMATION WE COLLECT AND HOW WE USE IT
Where do we collect information from?
The personal data we collect can come from the following sources:
- Directly from individuals or (in the case of certain patients) their authorized representatives/legal guardians
- Please note: if you provide us with personal data about another person (e.g., if you are a caregiver), you are telling us that you have the authority to share that data with us for us to use and share the data as described in this Privacy Notice
- From industry and patient groups and associations (including conference and event organizers)
- From health care professionals and their staff
- From publicly available sources, including information provided on websites, social media channels, public forums or platforms, and other third-party sources (including adverse event information or product quality complaints)
- From government agencies, civil servants and public records
- Through the Therakos Websites
What information do we collect and what do we use it for?
The types of information we collect will depend on your interactions with us. Please see the categories below.
In addition to the specific purposes outlined below, we may collect and use some of your personal information in order to:
- Provide and improve our products and services;
- Maintain and enhance our relationship with you, including by communicating with you;
- Comply with our legal and regulatory obligations;
- Protect our interests;
- Respond to emergencies;
- Protect the safety of persons and property; and
- Investigate, detect, and prevent fraud or other illegal or unauthorized activity.
Patients
Information we collect: We capture patient data through THERAKOS® CELLEX® Photopheresis devices, including data on patient treatment and certain patient-specific factors related to treatment such as patient height and weight. Most of this information is not identifiable, meaning that we don’t collect and maintain information about specific patients in a way that can be used to identify them. However, we may occasionally collect some limited identifiable patient information through this capture of treatment data.
If a patient contacts us regarding an experience with our products or services, including to report an adverse event, side effect, defect with a Therakos product or service, we may additionally collect the following personal information:
- Information about the individual who reported the adverse event or defect, including identifiers like name and contact information, relationship to the subject of the report, as well as professional or employment-related information, such as profession, when relevant to determining level of product expertise or medical expertise
- Information about the patient who experienced an adverse event, product complaint, or other product safety concern, including:
- identifiers like name or initials
- gender, weight, height, age or date of birth
- health and medical information relevant to the issue (such as details of the product associated with the report, details of other medications or other remedies the patient may be taking at the time of the report, details of the event or complaint, and other medical information or medical history that may be relevant to the complaint or may be required to be collected by law)
- Publicly posted information (such as online comments describing experiences with Therakos products or services, or any other concerns shared with Therakos)
- Any other information voluntarily provided to us by the patient or the individual reporting the adverse event or defect
What we use it for: We use aggregated and de-identified treatment data for the purposes of research and analytics, such as to measure the effectiveness of the treatment across the aggregated patient population.
If a patient contacts us with a concern about Therakos products or services, we will use the information to:
- communicate with the patient about their issues,
- respond to any specific requests received from the patient,
- investigate the adverse event or compliant, and
- meet our safety and quality monitoring obligations under applicable laws.
In some instances, we may be legally obligated to report some of this information to regulatory authorities, so we must keep some information about the patient reporting the concern to contact them for additional information. We may also share this information with our partners (as described in more detail below) if we are legally required or permitted to exchange safety and quality information with them.
Healthcare professionals
Information we collect: If you are a healthcare professional, we may collect the following types of information about you:
- Username and password that you may select in connection with establishing an account on the Therakos Websites, and any information you enter into the website through your online account
- Identifiers including business or personal contact information and preferences (such as name, email address, mailing address, or phone number)
- Professional or education-related information (such as job title, employer name, schools attended, degrees received, and relevant details about your professional practice)
- Professional achievements (such as licenses, certifications, or accreditations)
- Billing / payment information
- If you attend a public seminar or event, photographs, videos, audio recordings, or other recorded media of you
- Internet or other electronic network activity information (see “Interacting with us online” below for more details)
- Any information you choose to share with us during participation in our meetings, seminars, training sessions or events
What we use it for: We use this information for the purposes of establishing, managing, and enhancing our relationship with healthcare professionals, to communicate with you, and to ensure that we can continue to provide services to you. We may use information collected during a seminar or event for marketing and promotional purposes. Some of the information is collected and used for the purposes of meeting our legal and regulatory obligations and complying with our internal policies.
Users of our websites and individuals who engage with us online
Information we collect: If you use our website (regardless of whether you are a patient, healthcare professional, or other individual), or otherwise interact with us online (such as submitting inquiries to us or interacting with us on social media), we may collect the following information about you:
- Username and password that you may select in connection with establishing an account on the Therakos Websites
- Identifiers including personal and business contact information and preferences (such as name, email address, mailing address, phone number, or emergency contact information)
- Professional history or employment-related information (such as job title, employer name, and credentials) for healthcare professionals
- Biographical and demographic information, including date of birth, age or gender
- Publicly available information, including that on social media (such as comments describing support for or experience with Therakos products)
- Any information that you choose to provide to us through a webform, email message, mobile app, phone call, or other method of communication, which may also include sensitive information as defined under applicable law
- Internet or other electronic network activity information, including information about the use of our websites and mobile apps collected by automated means, such as cookies, web beacons, pixels, or other digital technologies.
What we use it for: Please see the section titled “Interacting with us online” below for details.
Participants in clinical trials or patient support programs
Clinical trials: If you are a participant in a clinical trial or other research study sponsored by Therakos, please contact the principal investigator for your study or refer to the informed consent form and other trial documents provided to you.
Support programs: We may collect the information about participants of our patient support programs. The type of information we collect and handle will depend on the specific patient support program. Normally, our patient support program providers will handle your personal information directly and do not share it with us unless necessary. If you enroll in any such program, we will provide you with more details about how your information will be handled at the time of enrollment. We will also provide you with the opportunity to consent to such handling of your information.
HOW WE SHARE YOUR INFORMATION
Our affiliates, partners, and service providers
Therakos may share personal information to third parties in order to provide our services, for the purposes described in this Privacy Notice, or for purposes that are separately communicated to you by Therakos. These parties include:
- Therakos affiliates
- Service providers that perform services or our behalf, including:
- Customer service and patient support providers
- Product recall service providers
- Technology service providers (e.g. tech support, email and web hosting, analytics providers, and cloud storage providers)
- Payment, shipping, and fulfillment service providers
- Third party partners with whom we jointly develop products or services (such as other pharmaceutical companies with whom we co-market, co-distribute, or otherwise collaborate on products)
- Third party partners that provide us with advertising and digital marketing services
When we share your information with our affiliates, partners and service providers, we ensure that it is protected and that it is not used for any other purposes.
Other third parties
We may also disclose personal information to other third parties for the following purposes:
- To legal and regulatory bodies worldwide including in connection with monitoring, products and services, adverse event reporting, and as otherwise required by law.
- As part of a corporate business transaction, such as a merger, acquisition, reorganization, joint venture or financing or sale of our assets, and could be sold or transferred to a third party as party of such a transaction.
- To comply with legal and regulatory requirements, and to protect Therakos (including our personnel, property, or interests). This includes protecting against fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile apps), and claims and other liabilities.
We do not sell or trade any personal information we collect.
INTERACTING WITH US ONLINE
Cookies and web analytics
Like many other websites, each Therakos Website uses cookies to collect information about website visitors. Cookies are small text files that are automatically deposited on a visitor’s device.
Information we collect via cookies helps us learn more about how the website is typically used, including the total number of visitors, which webpages they visit the most, the geographical location of the visitor, and the types of Internet browsers (e.g., Google Chrome, Firefox or Microsoft Edge) and operating systems (e.g., Windows or Apple MacOS) that our visitors use.
We use this information to improve the online services that we provide and to enhance the user experience and the overall quality of the website. We may also use this information for marketing and promotional purposes, such as to serve you with advertisements targeted towards your interests with our third-party social media advertising partners.
You can adjust your browser settings to disable cookies. To learn more about your Internet browser’s cookie options, please refer to instructions from your particular browser. Please note that if you adjust your browser settings to reject or disable certain cookies, the functionality of certain elements of the Therakos Websites may be impacted.
We also use Google Analytics to better understand how visitors interact with the Websites and our online advertisements, for the purposes described above. This includes information related to how many times a user visits the Websites, what pages they visit, and where they were referred from. To learn more about Google Analytics, click here. Users can deactivate the Google Analytics function with a browser add-on, which can be downloaded here.
Third party websites
Our website may include links to other websites that are operated or controlled by a third party. These websites are not governed by this Notice, and we encourage you to review any privacy policies associated with linked third-party websites.
OUR PRIVACY PRACTICES
Protecting your information
We maintain reasonable administrative, technical and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use. The precise safeguards we use depend on the sensitivity of the information in question.
Retention and destruction of information
We will retain your personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may governs the retention of the information, and our legal or regulatory obligations. We will then destroy your personal data or anonymize the information, in accordance with applicable law.
Cross-border transfers
We may transfer your personal information to partners, affiliates, service providers, or other trusted third parties that are located outside of your province or Canada, where it may be accessed, stored, or otherwise processed. We use appropriate safeguards to ensure that your personal information is protected no matter where it is used or stored.
When your personal information is transferred to a jurisdiction outside of your province or Canada, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
YOUR PRIVACY RIGHTS
Accessing and correcting your personal information
If you believe that the personal information we maintain about you is not correct, you can make a request to correct it by writing to the Privacy Officer using the contact information set out below. You may also request access to the personal information that we maintain about you by writing to the Privacy Officer.
We may need to verify your identity or obtain more information before responding to your request. In some cases, our legal obligations will prevent us from granting a request for access to or correction or personal information. We will inform you in writing of the reasons for any such decision.
Withdrawing your consent
You may have the right to withdraw the consent you have previously provided to process your personal data under certain circumstances. However, in some cases this may mean that we can no longer provide you with certain information, products, or services. Please contact the Privacy Officer using the contact information set out below for more information.
If you have signed up to receive marketing or promotional messages from us via email or text message, you always have the option to unsubscribe by emailing marketing@therakos.ca. You can do so by contacting us or using the unsubscribe mechanism contained in the message.
Additional rights
Depending on where you live, you may have the option to exercise additional privacy rights, in accordance with applicable provincial or territorial laws. Please contact the Privacy Officer using the contact information set out below for more information on your privacy rights.
UPDATES TO OUR PRIVACY NOTICE
Therakos reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.
CONTACT US
You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices. When raising a question, comment, or complaint, please provide sufficient details (including your relationship with us) and any relevant documentation.
The contact information for our Privacy Officer is:
Therakos UK Ltd.
Data Protection Officer
3 Lotus Park, The Causeway
Staines-Upon-Thames
TW18 3AG
England
Or via privacy@therakos.com