Last update of this Privacy Policy: October 26, 2021

Medicago Inc. (“Medicago,” “we,” “us” and “our” and includes its affiliates Medicago R&D Inc and Medicago USA Inc) offers online resources and communications that provide health, technology, and product-related information, as well as corporate news, employment and other information related to our business (the “Resources”).

Your privacy and the privacy of your personal information is important to us here at Medicago. Our Privacy Policy describes how your personal information is collected, used, and disclosed when you visit our corporate website at www.medicago.com or any other product website where a link to this Privacy Policy is displayed (the “Website”) or use our Resources (together with the Website, the “Services”).

This Privacy Policy does not apply to third-party online resources to which our Services may link (such as published studies and contributions), where we do not control the content or the privacy practices of such resources. We encourage you to learn about the data processing practices of these third parties and consult their privacy policies. We are not responsible for the content, operation or privacy practices of any such third-party online resources.

We want to make sure you understand what personal information we may collect about you when you interact with Medicago, how we use your personal information, and how we keep it safe.

By using the Services and/or providing us with your personal information, you are accepting and agreeing to this Privacy Policy.

If you have any questions, concerns or inquiries (including withdrawal of consent) regarding the collection, use or disclosure of your personal information or concerning this Privacy Policy, do not hesitate to reach out to us! You can e-mail us at legal@medicago.com, or reach us by mail at the following address:

MEDICAGO INC.

Legal Department

1020 Route de l’Église, Suite 600

Quebec, Quebec G1V 3V9

We will use reasonable efforts to respond within 30 days to any questions, concerns or inquiries you may have regarding access to your personal information.

What is personal information?

This Privacy Policy applies to personal information. The term “personal information” as used throughout this policy means any information relating to an identified or identifiable individual, including any data that identifies you directly or indirectly, or that could be used to identify, locate, contact or track your behavior or your preferences (including “cookies” and other electronic data).

For instance, some information may not be personal on their own but may become personal information if associated with other information or if the sum of the information allows us to identify individuals.

What personal information do we collect and for which reasons?

When you interact with us, we may collect personal information through the Website or the different Resources that we offer. You may access many parts of the Website and Resources without disclosing any personal information. Depending on your use of such Website and Resources, we may collect the following types of personal information:

  • Information provided by you. When you enter personal information into forms or data fields through our Services (such as your name and contact information), when you send any email communication or use the “contact us” section, as well as when you respond to any surveys or study you may choose to participate in (such as your name, phone number, date of birth, gender, height, weight, or other health information). The personal information collected may vary depending on your interaction with us but will be limited to that information necessary to record and manage our interaction with you or as permitted or required by law. When you apply for a job opening, you will be redirected to our human resource portal that will provide you with its own privacy policy and will collect relevant information for the job application.
  • Information from public or third-party information sources. We can also collect personal information when we monitor other websites. This may include your public personal information, for example when we monitor digital conversations on public platforms to understand what people are saying about Medicago or about the biotechnology industry in general. We may combine information that we have about you from various publicly available sources.
  • Usage Information. When you visit our Website or use our Services, we automatically collect information such as your web browser, IP address and domain used to access this Website, the type and version of your browser, time zone, individual web page browsing activity or products you view, referring/exit pages, and date/time stamps. We also collect information about websites or search terms referred you to our Website, and information about how you engage with us on the Website.

We may place what’s called a “cookie” on your computer to track your visit so that we can give you a better experience the next time that you visit our Website. Cookies are small data files that are placed on your device or computer through your web browser that is readable by the website that placed the cookie. Cookies can help us in many ways, for example, by allowing us to tailor the Website to better match your interests. Most websites use cookies, and most web browsers are set to accept cookies. If you choose not to be recognized, please refer to your Internet browser to erase cookies from your computer or hard drive or block all cookies or receive a warning before a cookie is stored. We may also use similar technology such as pixels, tags or web beacons to record information about how you browse our Website. Please refer to our “Cookie Policy” for more details.

We use this information to monitor our Website’s performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade the Website to provide you with a better experience the next time that you visit it.

We may use your personal information collected in accordance with this Privacy Policy to provide you with information and services including access to press releases, job postings and marketing information about us and/or our products and services or to provide you with updated information on our terms and conditions or Privacy Policy. We will obtain your consent before sending any marketing information where required by law.

Finally, we may use your personal information to comply with applicable laws and regulations, demands or requests made by regulators, governments, courts and law enforcement authorities. We may also use your personal information such as your location to improve our digital platforms available in certain areas, local content and services, or to monitor or analyze market trends in connection with our products, services and industry.

How is personal information disclosed with third parties? 

We do not sell your personal information.

We may disclose your personal information to affiliated companies, as the case may be, or with agents, partners and suppliers, including those who provide us with technology services such as data analytics, hosting, technical support, and auditing services.

We may also have to share your personal information with regulators, governments and law enforcement authorities as required. We will take all commercially reasonable measures to notify you prior to disclosing your personal information to law enforcements, unless we are prevented to do so by law.

We do not use personal information for any other purposes than to provide the Services, which means that we do not share, sell, rent, or trade any information with third parties for their promotional purposes. We do not have any marketing cookies installed within our Services.

If we go through a restructuration, a merger and acquisition or a sale of parts of all of our assets, personal information may also be transferred in such context, subject to any limitations under applicable laws. We will obtain appropriate assurances that personal information will be protected in these circumstances.

Your personal information may be transferred or accessed by entities outside of Canada in accordance with this Privacy Policy. We may transfer your personal information outside of your country of residence to countries or jurisdiction where we have facilities or engage third parties to provide services to us for the purposes outlined in this Privacy Policy.

How can you exercise your rights with respect to personal information?

Depending on where you are located, different rights are granted to you so that you can control how we process your personal data. These rights generally include the rights to access and rectify personal data. In some cases, where we are required to retain information by law, or to ensure that we honor your preferences, or for other legitimate business purposes, we may not be able to delete certain personal information about you. Further, we may not be able to accommodate your request if such request is unreasonably repetitive, requires disproportionate technical efforts or jeopardizes the privacy of others.

Namely, in the European Union, additional rights may include:

  • The right to be informed about how we process your personal data;
  • The right to request the erasure of your personal data;
  • The right to revoke your consent when our processing is based on your consent;
  • The right to object to the processing of your personal data;
  • The right to restrict the processing of your personal data;
  • The right to have automated decision making reviewed in accordance with the law;
  • The right to the portability of your personal data;

Some of these rights may not be applicable, depending on the circumstances.

If you reach out to us to exercise your rights, we will respond to you within 30 days of receiving your request, or faster if required by applicable laws. In some cases, we may need additional information to validate your identity. We will only use this information for this purpose. If you do not agree with how we responded to your request, you have the right to lodge a complaint with your local authorities.

If you are located in Canada, the Officer of the Privacy Commissioner of Canada (OPC) drafted this FAQ to help you access your personal information when it is held by a business: Office of the Privacy Commissioner of Canada – Office of the Privacy Commissioner of Canada.

You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:

Telephone

9:00 am to 4:00 pm EST

Toll-free: 1-800-282-1376

Mailing address

Office of the Privacy Commissioner

30 Victoria Street

Gatineau, Québec

K1A 1H3

If you’re not satisfied with how we process your request, you can lodge a complaint with the OPC.

How do we protect your personal information?

We seek to implement controls – including administrative, technical and physical measures – to safeguard your personal information against loss, theft and misuse, as well as against unauthorized access, disclosure, alteration and destruction, according to the sensitivity of the information and taking into account the risks to your privacy. For instance, we use multi-factor authentication, SSL encryption, physical access controls to files and buildings and secure file transfer protocols with encryption. Where relevant, the Website uses Transport Layer Security (TLS) encryption on all web pages where personal information may be collected from. It is highly recommended to use a TLS-enabled browser. Doing so protects the confidentiality of your personal information while it is transmitted over the Internet. We also expect our service providers to provide adequate level of security for personal information.

How long will we keep your personal information?

We will keep your personal information for as long as reasonably needed for the specific purpose(s) for which it was collected. In some instances, we will keep your personal information for a longer period of time, as permitted or required by law or where we need to do so in connection with legal action or an investigation involving Medicago.

Can we modify this Privacy Policy?

We may change this Privacy Policy from time to time, such as to reflect additional functionalities or data processing practices. We encourage you to review this Privacy Policy periodically. We will also provide an update notice at the beginning of this Privacy Policy to inform users when the changes we make to this Privacy Policy are material. However, we will not materially change this Privacy Policy or our practices to make them less protective of users’ privacy.

Should you have any questions about this policy or our personal information processing practices, you may contact us at legal@medicago.com