Privacy Policy

1. Our Commitment to Privacy

Octapharma Canada Inc. (“Octapharma,” “we,” “us”) is committed to protecting the personal information of all visitors to TreatTheBleed.org (the “Website”) in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), Canada’s anti-spam legislation (“CASL”), and applicable provincial health-privacy laws such as Ontario’s Personal Health Information Protection Act (“PHIPA”) where relevant.

This Privacy Statement explains what information we collect, why we collect it, how we use it, and the choices you have. By using the Website you consent to the practices described below. If you do not agree, please discontinue use of the Website.

2. Ten Privacy Principles (PIPEDA Alignment)

We adhere to the ten fair-information principles set out in PIPEDA:

Accountability – A designated Privacy Officer oversees compliance.
Identifying Purposes – We clearly state why data is collected (see §4).
Consent – We obtain meaningful consent before collecting, using, or disclosing personal information, except where otherwise permitted or required by law.
Limiting Collection – We collect only what is necessary for the identified purposes.
Limiting Use, Disclosure & Retention – Information is used and disclosed solely for the stated purposes and retained only as long as needed (see §8).
Accuracy – We keep personal information as accurate, complete, and up-to-date as necessary.
Safeguards – We protect personal information with appropriate technical, administrative, and physical measures (see §7).
Openness – This Statement details our policies and practices.
Individual Access – You can request access to or correction of your personal information (see §9).
Challenging Compliance – You may contact our Privacy Officer with questions or complaints (see §11).

3. Scope

This Statement applies to:

All personal information collected through the Website, including the Learning Management System (“LMS“) and interactive tools;
Email and SMS communications sent by Octapharma related to the Website;
Personal information submitted when reporting adverse events or product-quality complaints.

It does not cover aggregated or anonymized data that cannot be linked to an identifiable individual.

4. What We Collect & Why

4.1 Information You Provide Voluntarily

Category	Examples	Purpose
Identity & Contact	Name, professional designation, email address, employer	Account creation, LMS progress tracking, event registration, CASL-compliant email updates
Professional Details	Specialty, licence number (optional)	Tailoring educational content to your practice area
User-Generated Content	Survey responses, quiz answers, forum posts	Continuous improvement of educational materials; research & analytics (de-identified)
Adverse-Event Reports	Patient initials, age, sex, adverse-event details	Regulatory pharmacovigilance reporting (legal obligation)

4.2 Information Collected Automatically

Device & Usage Data – IP address, browser type, operating system, pages visited, session timestamps; used for security, analytics, and site optimization.
Cookies & Similar Technologies – Functional cookies remember preferences; analytics cookies measure traffic; optional marketing cookies (disabled by default) help us understand engagement. You may adjust cookie settings via the cookie banner or your browser. Disabling cookies may affect certain features.

4.3 Legal Bases for Processing

Basis	Typical Scenarios
Consent	Account registration, newsletters, non-mandatory surveys
Legal Obligation	Adverse-event reporting to Health Canada under the Food and Drugs Act
Legitimate Interest	Site security, aggregated analytics, fraud prevention

5. How We Use Personal Information

Provide & Administer Services – authenticate users, deliver LMS modules, issue certificates of completion.
Educational Analytics – track learning outcomes in de-identified form to improve content.
Regulatory Compliance – fulfil pharmacovigilance obligations.
Communications – send CASL-compliant email updates or reminders (opt-in, with unsubscribe link).
Research & Quality Improvement – analyze usage trends in aggregate to enhance Website performance.

We do not use personal information for automated decision-making or profiling that produces legal or similarly significant effects.

6. Disclosure & Cross-Border Transfers

We share personal information only:

With your consent;
With service providers (e.g., cloud hosting, LMS vendor, email platform) under written agreements that require PIPEDA-level protection. Some providers may process data outside Canada (e.g., the United States or EU). Where data leaves Canada, it may be subject to foreign laws and accessible to foreign authorities. We conduct risk assessments and use contractual safeguards (e.g., Standard Contractual Clauses) to protect your information.
For legal reasons – to Health Canada or other authorities when required by law (e.g., safety reporting) or to protect the rights, property, or safety of Octapharma or others.

We never sell personal information.

7. Safeguards

Technical – TLS encryption in transit; AES-256 encryption at rest; multi-factor authentication for privileged accounts; regular penetration testing.
Administrative – Privacy & security training; role-based access; vendor due-diligence processes.
Physical – Secure data centres with access controls.

8. Retention & Disposal

Personal information is retained only as long as necessary to fulfil the purposes set out in this Statement or to meet legal/regulatory retention requirements (e.g., 25 years for pharmacovigilance data). When no longer required, we securely destroy, erase, or anonymize the data.

9. Your Rights & Choices

Under PIPEDA (and PHIPA, if applicable) you have the right to:

Access the personal information we hold about you;
Request Correction of inaccurate or incomplete information;
Withdraw Consent (subject to legal or contractual restrictions); this may limit your ability to use certain features;
Challenge Compliance by filing a complaint with our Privacy Officer or the Office of the Privacy Commissioner of Canada.

To exercise any of these rights, please contact us (see §11). We may need to verify your identity before proceeding.

10. Electronic Communications & CASL Compliance

We send commercial electronic messages (“CEMs”) only with express or implied consent as defined under CASL. Each CEM will:

Identify Octapharma as the sender;
Provide our mailing address and contact details; and
Include a no-cost, one-click unsubscribe mechanism effective within 10 business days.

11. Contact & Privacy Officer

Privacy Officer
Octapharma Canada Inc.
25 King St W, Suite 1000, Commerce Court Box 328
Toronto, ON M5L 1G1
Email: info.canada@octapharma.ca

12. Changes to This Statement

We may update this Privacy Statement periodically. The “Last updated” date at the top indicates the effective date. Material changes will be announced via a notice on the Website or by email where appropriate. Continued use of the Website after the effective date constitutes acceptance of the revised Statement.

Last updated: 5 June 2025