Privacy Policy

This Privacy Policy was last updated on November 15, 2018.

Searchlight Pharma Inc. (the “Company”) created this official privacy policy (the “Privacy Policy”) to set forth its privacy practices for Nextstellis.ca (the “Site”). The Company respects your privacy and is committed to protecting it through compliance with this policy. By using the Site, or by providing us with personal information, you agree to all of the terms and conditions of the Privacy Policy. Please be sure to read this entire Privacy Policy before using the Site or submitting personal information. If you disagree with or do not accept any part of the Privacy Policy, do not use the Site or submit any information.

The Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the Site, and our practices for collecting, using, maintaining, protecting, and disclosing that information. The Privacy Policy details our commitment to your privacy, including:

the types of information the Company collects and how it collects this information;
how the Company uses and may disclose the information it collects;
the measures the Company takes to secure and protect the information it collects;
how the Company secures and protects Personal Information; and
how you can contact the Company

The Privacy Policy applies to information we collect: (a) on the Site; (b) in email and other electronic messages between you and the Site; and (c) through any mobile and desktop applications you download from the Site.

The Privacy Policy does not apply to information collected by: (a) the Company through any other means, including on any other website owned or operated by the Company or information collected offline; or (b) any third party including through any third-party application or content, including advertising, that may link to or be accessible from, or on, the Site.

1. Collection of Information

(a) Active Collection of Personal Information

The Company may collect information you provide in connection with your access to and use of the Site. This includes, but is not limited to, any comments, suggestions, or other information that you provide on, through, or relating to the Site, and/or that relates to the Company’s products or the Company. This also includes records and copies of correspondence, including personal and contact information that you generate if you contact us or provide if you would like us to contact you; responses to surveys that we may ask you to fill out for research and marketing purposes; and your search queries. This information is necessary for the adequate performance of contracts between you and us, if any, to enable us to comply with legal obligations, and given our legitimate interest in being able to provide and improve the functionalities of the Site.

(b) Passive Collection of Information through Tracking Technology

The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to help analyze how users use the Site. Google Analytics uses “cookies” and other tracking technology to collect aggregate data (“Aggregate Data”) from your visits to the Site. Cookies are text files the Site places in your computer’s browser to store your preferences. Cookies do not cause damage to your computer system or files. Your browser should allow you to delete existing cookies, decline cookies, or give you the choice of declining or accepting cookies. Your personal information will not be extracted from the cookies. To learn more about the privacy policy of Google Analytics, refer to Google’s Policies and Principles. Use the Google Analytics Opt-out Browser Add-on to prevent analytics information from being sent to Google Analytics. The Company stores any Aggregate Data we collect from you in aggregate form. The Company is not able to identify any particular user or individual from the Aggregate Data. The Company uses the Aggregate Data it collects in a variety of ways, including but not limited to keeping count of your return visits to the Site, accumulating and reporting aggregate statistical information regarding the Site, and determining which features users prefer.

In addition to Google Analytics, we may also use automatically-collected information that helps us to customize the Site to match our users’ individual interests and recognize returning users, estimate the number of website-users and their usage patterns, and increase the speed of our users’ searches. We may use the below tools to collect this data:

“Pixel tags,” “web beacons,” “clear GIFs,” or similar means (collectively, “Pixel Tags”). We use these small electronic files to compile aggregate statistics about Site usage and response rates. Pixel Tags allow the Company to count the number of users who have visited certain pages of the Site, to deliver branded services, and to help the Company determine the effectiveness of its promotional or advertising campaigns as well as the effectiveness of the Site itself. When Pixel Tags are used in HTML-formatted email messages, they can tell the sender whether and when the email has been opened.
Referrers and your Internet Protocol (IP) Address. Referrers are small files containing information your web browser passes to the Company’s web server that references the URL which you used to access the Site. Your IP address is the number used by computers on the network to identify your computer so that you can receive data.
Environmental variables. Environmental variables include, but are not limited to, the domain from which you access the Internet, the time you accessed the Site, the type of web browser, operating system, and platform your computer uses, the Internet address of the previous website you visited before entering the Site, the names of the pages you visit while at the Site, and the next Internet website you visit after leaving the Site.

(c) Other Sources

To the extent permitted by applicable law, and with your consent as required by applicable law, the Company may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, the Company may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts.

2. How We Use and Disclose Information

You understand and agree that the Company may use and/or disclose your information (including your Personal Information) as follows:

(a) Your Consent. Where you have provided consent, we may use or share your information, including personal information, as described at the time of consent.

(b) Our Business Purposes. We may use your information for the Company’s everyday business purposes such as to (1) provide products and/or services to you including through our subsidiaries and affiliates, (2) with your consent as required by applicable law, communicate updates, promotions, or news about the Company, its products, or events through email or direct mail, (3) market our products and services, (4) monitor and conduct reviews of the Company’s products and offers, (5) help the Company improve its current products or develop new products, (6) collect demographic and geographic information about the users of the Site and its products, (7) communicate administrative or legislative related information, and (8) fulfill any other purpose for which you provide the information.

(c) Service Providers. The Company uses a variety of third-party service providers to help us provide services related to the Site and our products and services. Service providers may be located inside or outside of Canada, including in the United States or the European Economic Area (“EEA”). These providers have limited access to your information to perform tasks on our behalf, such as website and software optimization, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy. The Company will need to share your information, including personal information, in order to ensure the adequate performance of any contract with you and given our legitimate interest in being able to provide and improve the functionalities of the Site, as described in this Privacy Policy.

(d) Business Transactions. The Company reserves the right to transfer any information collected, including personal information, in the event of a transfer of ownership, assets, securities, or bankruptcy involving the Company and in connection with Company business transactions such as buying or selling subsidiaries or engaging in joint ventures with third parties; provided, however, the Company will use reasonable efforts to notify you before your personal information is transferred.

(e) Compliance with Law. The Company may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations; (ii) to comply with legal process and/or to respond to claims asserted against the Company; (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability; (iv) to enforce and administer our Terms of Use or any other agreement we have with you; or (v) to protect the rights, property, or personal safety of the Company, its employees, or members of the public.

Where we consider it appropriate, we may notify you about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order, or by applicable law; or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud or other liability upon the Company.

(f) Subsidiaries and Affiliates; Third Parties. We may disclose your information to the Company’s subsidiaries and other affiliates for the purposes set out in this Privacy Policy. Further, to the extent you have consented in accordance with the applicable law, we may release your information to third parties to market their products or services to you. We require these third parties to keep your information confidential and use it only for the purposes for which we disclose it to them.

(g) Aggregated Data. The Company may share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

(h) Compliance with Terms of Use. We may disclose Personal Information in order to enforce our Terms of Use and any other agreements.

3. Your Responsibilities and Choices

(a) User Generated Content Functions

This Site may allow you to submit your own content to the Site through various Site functions. Any content that you submit to or for use on a public area of the Site may become public. You should exercise caution if any content you submit includes any information about yourself, including any personal information. You may not submit the personal information of others unless you have their consent. The Company is not responsible for the results of such submissions and it cannot prevent such information from being used by third parties in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety. By submitting any User Content to the Site, you signify your acceptance of, and agreement to follow and be bound by, the Terms of Use and the Privacy Policy.

(b) Accuracy and Confidentiality

It is your responsibility to provide current, complete, truthful, and accurate information, and to keep such information up to date. The Company cannot and will not be responsible for any liability or other problems that may arise from your failure to enter current, complete, truthful, and/or accurate information, or your failure to update such information. You, not the Company, are solely responsible and liable for your activity, behavior, use, and conduct on the Site or any other activity or conduct in connection with the Site. Any submission of information by you does not guarantee that the Company will permit you to use any or all of the features or functions of the Site.

(c) Communication with Users; Opt-Outs; Attempted Fraud

The Company may contact users who have entered personal information in connection with the Site, for example to respond to a question you have asked. If you have agreed to receive marketing and promotional emails from us, you may “opt out” of receiving such emails by following the opt-out procedure described in each email the Company sends. However, even if you opt out of receiving marketing and promotional emails, the Company may continue to email you for administrative or legal purposes, including follow-up messages regarding any content you have submitted to the Site.

You may also set your internet browser to disable or refuse some or all browser cookies, to alert you when cookies are being set, and to delete some or all cookies once received. However, if you disable or refuse cookies, some parts of the Site may not function properly.

The Company does not and will not send you emails asking you to provide or confirm sensitive personal information. A technique known as “phishing” attempts to steal personal identity data and financial account credentials from consumers. “Phishers” use “spoofed” emails to lead consumers to sham websites which trick recipients into divulging personal information including credit card numbers, account usernames, passwords, and social insurance numbers. If you receive such an email communication purporting to be from Nextstellis.ca, please forward it immediately to [email protected] and then delete it from your computer.

4. Third-Party Websites

The Site may provide links to third-party websites. These websites operate independently from the Company and may have their own privacy policies or statements. We encourage you to review the privacy policy of any third-party website or resource before using it. You accept sole responsibility for and assume all risk arising from your use of any such websites or resources.

5. Security and Protection of Personal Information

The Company does not sell, rent, or trade any personal information you provide to the Company, nor does it disclose any such personal information to any third parties outside the Company except as specified under this Privacy Policy and except in those specific instances when a user gives the Company specific permission to do so. The Company does not sell, lease, or rent any email lists to third parties.

The Company uses firewalls and physical, operational, and technological controls to help maintain security and confidentiality on the Site to protect against unauthorized disclosures, use, alteration, or destruction of the information you provide to the Site. The Company limits access to the databases containing information to its key personnel who need such information for the purposes indicated in this Privacy Policy, or such other purposes as may be permitted or required by the applicable law. Personal information we collect is maintained at Amazon Web Services.

However, the security of your Personal Information also depends on you. The Company cannot guarantee the security of Personal Information, and, therefore, any transmission of Personal Information is at your own risk. We also cannot guarantee that information you provide to us over the Internet will not be intercepted.

6. Access to Personal Information; Company Rights

(a) Your Right to Access and Correct your Personal Information

You have a right to request access to your personal information in our control, and to request a correction to it if you believe it is inaccurate. If you have submitted personal information to Company and would like to have access to it, or if you would like to have it removed or corrected, please contact us using the contact information provided below. Please note that in some cases we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons. We may require you to verify your identity before allowing you to access your personal information.

(b) The Company’s Rights

The Company reserves the right to deny access and/or use privileges to any user, including without limitation, of any services, features, or functions of the Site if there is a question regarding the identity of the person accessing or attempting to access any services, features, or functions.

7. Your Rights and Contacting Us

If you have any questions, requests, or concerns related to this Privacy Policy or would like to exercise any of the rights described in this section or Privacy Policy, you may contact us by emailing us at [email protected] or by writing to our President and General Manager, at the following address:

Searchlight Pharma Inc.
1600 Notre Dame St. West, Suite 312
Montréal, Québec H3J 1M1

(a) Managing Your Information. You have the right to subscribe or unsubscribe to content from the Company.

(b) Correction of Inaccurate or Incomplete Information. You have the right to ask the Company to correct inaccurate or incomplete personal information concerning you.

(c) Data Access. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by the Company. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format.

(d) Data Retention and Erasure. The Company generally retains your personal information for as long as is necessary for the performance of contracts between you and us, if any, for the purposes described in this Privacy Policy, or to comply with our legal obligations. If you no longer want the Company to use your information, you can request that we erase your personal information. Please note that if you request the erasure of your personal information as permitted by applicable law:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
We may retain and use your personal information to the extent necessary to comply with our legal obligations.
Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Residual copies of your personal information may not be removed from our backup systems for a limited period of time.

(e) Withdrawing Consent and Restriction of Processing. Where you have provided your consent to the processing of your personal information by the Company you may withdraw your consent at any time by sending a communication to the Company specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing of your personal information is unlawful and you oppose the erasure of such information; or (iii) we no longer need your personal information for the purposes of the processing, but you have requested access to it.

(f) Objection to Processing. In some jurisdictions, applicable law may entitle you to require the Company not to process your personal information for certain specific purposes (including profiling). If you object to such processing, the Company will no longer process your personal information for these purposes unless we are permitted to do so by applicable law, such as for the exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time, ask the Company to cease processing your data for these direct marketing purposes.

(g) Lodging Complaints. You have the right to lodge complaints about the data processing activities carried out by the Company before the competent data protection authorities.

8. Notification of Changes

The Company reserves the right, in its sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time by updating this posting without advance notice to you. You agree that the Company may notify you of material changes to this policy by indicating the date of the most recent update at the top of the policy, and that you will check the Site frequently for updates. If at any point the Company decides to use your information in a manner different from that stated at the time it was collected, the Company will notify you and you will be given a choice as to whether the Company may use this information in the new manner.

9. Tracking

At this time, the Site does not respond to web browser “do not track” signals. We may add this functionality in the future, and if we do, we will update this Privacy Policy to let you know.

10. Children’s Privacy

We are committed to helping protect the privacy of children. We do not knowingly collect personal information from children under the age of 18.

11. Operating Globally

(a) General

To facilitate our global operations, the Company may transfer, store, and process your information within the Company or with service providers based in Europe, India, Asia-Pacific, and/or North and South America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within Canada may be transferred, stored, and processed outside of Canada for the purposes described in this Privacy Policy. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

Where we transfer, store, and process your personal information outside of Canada we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

Searchlight Pharma Inc., and its subsidiaries Aralez Pharmaceuticals Canada Inc. and Nuvo Pharmaceuticals (Ireland) Designated Activity Company (“Searchlight”, “us” or “we”) is committed to protecting your Personal Information (as defined below) in accordance with this Privacy Policy (“Policy”).

This Policy governs the collection, use and disclosure of your Personal Information with respect to any communication or interaction you may have with us, whether it be in person, over the telephone, in writing, or electronically.

We comply with all of the requirements of Canada’s federal Personal Information Protection and Electronic Documents Act, other applicable substantially similar provincial legislation and, where applicable, the European Union General Data Protection Regulation (“GDPR”) 2018 (collectively “Data Protection Legislation”).

By submitting to us your Personal Information, using Searchlight’s website (the “Site”), purchasing one of our products or otherwise interacting with us, you (“you”, “Data Subject”) accept this Policy and are deemed to explicitly consent to its terms and terms otherwise described to you at the time of collection of your Personal Information. You may withdraw this consent at any time, unless legal requirements prevent your withdrawal. If we are asking you to provide sensitive Personal Information, in addition to this Policy we will always tell you why and how this information will be used. If you do not agree with the terms of this Policy, please do not use the Site or otherwise provide your Personal Information to us.

This Policy may be amended at Searchlight’s discretion. Any changes we make will become effective when we post an amended version of the policy on our Site. Please check back from time to time for such amendments. If the changes we make are significant, we will provide a more prominent notice where required by applicable laws. By continuing to access and use the Site or our services, or purchase our products after the modified version of the Policy has been posted or you have been informed of such update, you agree to the terms of the then-current Policy, as amended. If you do not agree to the changes in the Policy, it is your responsibility to stop using our Site or our services, or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the Policy. The “Effective Date” at the top of the Policy indicates when it was last updated.

What is Personal Information?

“Personal Information” is information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. It may also include other types of more technical information, but only when this information can identify you as an individual. Business contact information or information from a public directory listing of your name, address, or telephone number is not Personal Information. Information that is aggregated or de-identified and cannot be associated with an identifiable individual is not considered to be Personal Information. Please note that the definition of Personal Information may differ in various jurisdictions.

Collection of Personal Information

Personal Information is collected by Searchlight when you provide it to us, for example via the Site or when you call or email us, or buy one of our products. We may also collect information through automated technologies, such as your browsing activity and your IP address when you use the Site and we keep track of your dealings with us, including details of your visits to our Site and the resources that you access, including, but not limited to, traffic data, location data, and other communication data. For more details on our collection through cookies and similar technologies, please the section entitled “Use of Cookies and Other Technologies” below.

Personal Information that we collect may include:

Contact information, such as your name, email and postal address, telephone number;
Transactional information, such as purchases made (e.g. the number and amount of transactions by type, product code information, quantity purchased, date, time, payment method used, etc.);
Browsing activity on our Site and other technical information, such as browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, IP address, the equipment you use to access our Site, and usage details;
Payment information, such as payment card numbers when you make purchases;
Geolocation information may be collected when you use our Site, although this information may not always identify you as an individual; and
Any other information you provide to us.

We collect your Personal Information for the purposes of improving our business and its communications and answering the questions you pose to us and responding to comments you make to us, with respect to our products, investing in Searchlight, employment opportunities and otherwise. We may also de-identify your Personal Information and use the resulting data for market research, business optimization and other purposes.

Use of Personal Information

We may use the Personal Information we collect to provide you with our products and services, to manage our business operations and process employment applications, to communicate offers and information we think might interest you, to conduct research, and as otherwise permitted or required by law. More specifically, we may use your Personal Information for the following purposes:

Providing Products and Services. We use your Personal Information in order to provide products and services, including:
- verifying your identity;
- providing products and services;
- processing your transactions and returns;
- taking instructions from you;
- creating, administering, and maintaining your account; and
- fulfilling your requests and responding to your comments and inquiries.
Managing Our Operations. We use your Personal Information to manage our operations, including:
- deploying and managing our information technology applications and systems, including managing our Site;
- maintaining our services;
- notifying you of changes to our services, terms, conditions or policies and to provide you administrative messages, legal notices, or other information;
- meeting our contractual and legal obligations;
- maintaining the security of the public, our customers and our employees;
- responding to inquiries about investing in Searchlight and employment opportunities; and
- protecting ourselves and third parties from errors and fraud.
Marketing. If you indicate that you are interested in receiving offers or information from Searchlight, your Personal Information will also be used to contact you or to send you materials about products, services and investment opportunities that might be of interest to you. We may do this by communicating with you in a variety of ways, such as by email, telephone, direct mail, or text message. For more information on managing your preferences, please see “Marketing Communications”, below
Research and Analytics. We may also de-identify your Personal Information and use the resulting data for market research, business optimization and other purposes, including:
- improving or developing new products or services;
- managing and improving our operations;
- understanding our customers’ interests and priorities and tailoring our products and services;
- measuring the effectiveness of our marketing and promotional activities; and
- understanding how visitors interact with our Site and ensuring it functions properly.

We collect and use your Personal Information only for the purposes described above and other purposes disclosed to you at the time of collection or as permitted by law.

How We Share Personal Information

We may share or disclose information as provided below:

Affiliates. Searchlight and its affiliates may share Personal Information with each other and use it for the purposes described in this policy. This allows Searchlight and each entity within the corporate group to comply with applicable laws, regulations and requirements and ensures that your information is consistent and up-to-date.
Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our Site, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
Business Transactions. If another company acquires, or plans to acquire, our company, business, or our assets, or if we undergo a reorganization or financing of parts of our business (including the proceedings of insolvency or bankruptcy), we may share information with other parties to the transaction, including at the negotiation stage.
As Permitted or Required by Law. Applicable laws may permit or require the use, sharing, or disclosure of Personal Information without consent in specific circumstances. These circumstances include situations where it is necessary to disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of persons or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary. If this happens, we will not share more Personal Information than is reasonably required to fulfill that particular purpose.

We do not disclose your Personal Information, except as disclosed to you in this Policy, at the time of collection, or as permitted or required by law.

Cross Border Transfers of Personal Information

Your Personal Information may be processed and stored outside of the location in which it was collected by us or a third party service provider, or outside of the jurisdiction where we are located or where you reside (“Location”), subject to local law. If your Personal Information is transferred outside of such Location, your Personal Information will be subject to the laws of the country in which it is processed or stored. In certain circumstances, foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal Information without notice to you. Where required by applicable Data Protection Legislation, Searchlight will complete continual reviews of the countries with sufficient adequacy decisions, and provisions for binding corporate rules, standard data protection clauses or approved codes of conduct. Searchlight will further perform due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information.

Searchlight undertakes that it shall not transfer Personal Information outside of the Location unless the following conditions are fulfilled:

The Data Subject has enforceable rights and effective legal remedies;
Searchlight shall comply with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Information that is transferred;
Searchlight complies with any reasonable instructions notified to it in advance with respect to the processing of the Personal Information; and
Upon written direction shall delete or return, where applicable, Personal Information (and any copies of it) unless Searchlight is required by law to retain the Personal Information.

Our legal basis for processing your processing your Personal Information, depending on the jurisdiction in which you reside, is based upon your consent to do so, performance of a contract where you are a party, legal obligations we are required to meet, and the Data Protection Legislation provisions.

Security

We implement reasonable security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We use physical, organizational, and technological measures to protect Personal Information. We maintain policies and practices to protect your information that :

Provide a framework for our handling of your Personal Information;
Define roles and responsibilities within Searchlight for handling your information from the time it is collected to when it is destroyed; and
Govern our internal process for dealing with complaints regarding the protection of Personal Information.

We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected or as required by the Data Protection Legislation.

Information transmitted on the internet, especially by electronic mail, is never 100% secure. As a result, you should take special care in deciding what information you send to Searchlight by electronic mail.

Use of Cookies and Other Technologies

For the improvement of the Site and customer services, the Site may make use of cookies, which automatically collect anonymous user data (such as user traffic patterns and server activity). A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer, allowing the Site administrator to identify your computer and passively track your activities on the Site.

We may use cookies to temporarily store some Personal Information, such as to save your password, so you don’t have to re-enter it each time you visit our Site. Cookies, by themselves, cannot be used to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Site. Most browsers are initially set up to accept cookies, but you can set your browser to refuse cookies. However, if you do not accept cookies, your access may be limited in some areas of the Site.

The Site may also use Web beacon, gif, or other technologies. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

Marketing Communications

You may choose to provide us with your email address for the purpose of allowing us to send promotional materials to you, including information about products, services and investment opportunities that might be of interest to you, as well as offers from third parties. If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message. Please note that:

Even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes, in compliance with applicable laws (e.g., for customer service, product information, service or reminder notices, or recalls). We may also need to contact you with questions or information regarding your customer service inquiries; and
It may take some time for all of our records to reflect changes in your preferences.

Managing Consent

By using our Site, purchasing products or otherwise interacting with us, you are providing your consent to the collection, use and disclosure of Personal Information as set out in this Policy. In some cases, your consent may be “implied”, i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your Personal Information.

You may be entitled under applicable law to withdraw your consent (except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us). If you choose not to provide us with certain Personal Information or if you withdraw your consent, where such withdrawal is available, we may not be able to provide you with our services. You may withdraw consent to processing (where such processing is based upon consent) by contacting us at the address provided in the “Contact Us” section below.

Your Rights as a Data Subject

Depending on the jurisdiction in which you reside, at any point while we are in possession of or processing your personal data, you, the Data Subject, may have one or more of the following rights, where applicable:

Right of access – you have the right to request a copy of the information that we hold about you. In order to access your Personal Information, you must put your request in writing to our Privacy Officer, referred to below. Please allow up to thirty (30) days for a response;
Right of rectification – you may have a right to correct data that we hold about you that is inaccurate or incomplete;
Right to be forgotten – in certain circumstances you may ask for the data we hold about you to be erased from our records;
Right to restriction of processing – where certain conditions apply you may have a right to restrict the processing;
Right of portability – you may have the right to have the data we hold about you transferred to another organisation;
Right to object – you may have the right to object to certain types of processing such as direct marketing;
Right to object to automated processing, including profiling – you may also have the right to object to the legal effects of automated processing or profiling; and
Right to review, in the event that Searchlight refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

Please note that the exercise of your rights may be subject to applicable legal restrictions. We may take reasonable steps to verify your identity before fulfilling your request.

Third Party Websites

Please be aware that the Site may, from time to time, contain links to other third party websites and Searchlight does not represent and cannot guarantee that those websites have privacy policies similar to this Policy. Searchlight disclaims all liability in relation to such third parties.

Contact Us

Searchlight has a designated Privacy Officer. If you have questions, comments or complaints about this Privacy Policy, or if you wish to withdraw your consent to Personal Information that we have collected about you, please contact our Privacy Officer at [email protected] or at:

Privacy Officer:

1600 Notre-Dame Street West, Suite 312
Montreal, Quebec H3J 1M1
Canada

DOC Dublin Airport
Balheary Road
Swords, Co Dublin, Ireland
K67E5AO

November 11, 2023

Searchlight Pharma Inc.
1600 Notre Dame St. West, Suite 312
Montréal, Québec H3J 1M1

NEXTSTELLIS is a trademark of Searchlight Pharma Inc.