Privacy Policy

Our Commitment to Privacy

Genealis Pharmaceutical Inc. is committed to protecting the privacy of personal information in our possession. Recognizing that we operate in compliance with Canadian privacy laws, Genealis will make every effort reasonable to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation pertaining to the protection of personal information.

Scope

This Genealis privacy policy applies to those individuals whose personal information Genealis collects, uses, or discloses in the course of its commercial activities. Personal information is collected and processed by Genealis and its trusted partners who may be located in Canada or elsewhere in the world.

A separate employee policy governs Genealis's use of employee personal information.

About Genealis

Genealis Pharmaceutical Inc. is a pharmaceutical company incorporated under the laws of Ontario, Canada, specializing in the development of generic drugs and nutraceuticals.

Definitions

For the purposes of this privacy policy:

• 'Handling' refers to the collection, use, processing, storing, or disclosing of personal information.
• 'Healthcare practitioner' means any person or institution, such as a doctor, pharmacist, dentist, or nurse, who provides medical care or health services to a patient or is part of a patient's circle of care.
• 'Personal information' refers to any information that either alone, or together with other information, can be used to identify an individual. In Canada, 'personal information' means information about an identifiable individual, but does not include the business contact information of an employee of an organization.

Collection

Whose information do we collect?

In the course of doing business, Genealis may collect the personal information of individuals such as: customers, consumers, patients, website visitors, potential business partners, and individuals who contact us for information.

Sources of personal information

Genealis may obtain personal information from an individual directly or indirectly. This collection of personal information may occur through various means: through the telephone; via our contact forms; through your use of our website; or through data transfers from third parties.

Types of personal information

Depending on the individual, personal information may include:

• Contact information (name, email address, phone number)
• Professional credentials and affiliations
• Message content and inquiries
• Website usage data (IP address, browser information, pages visited)
• Communication preferences

Limiting collection

Genealis only collects personal information to the extent required to carry out the purpose of such collection, to provide you with information about our products or services, or to communicate with you for business purposes. We limit collection to individuals 18 years of age and older.

Use

Genealis collects personal information in the course of its day-to-day business activities, which include:

• Responding to inquiries about our products and services
• Providing information about pharmaceutical developments
• Processing contact form submissions
• Accepting job applications and recruitment
• Conducting business development activities
• Maintaining and improving our website
• Complying with regulatory requirements

Complaints and Inquiries

Any personal information you disclose when contacting Genealis will be used to process and respond to inquiries, complaints, or product questions.

Cookies and Website Analytics

When you visit our website, we may collect information about your computer or electronic device (e.g., your Internet Protocol (IP) address, browser type, and date and time of your request) by using automatic systems such as cookies and analytics tools including StatCounter. These technologies help us understand how visitors interact with our website and improve our services. You may limit or remove cookies from your computer or device, but this may limit our ability to provide optimal service.

Disclosure

By Genealis and our Affiliates

When personal information is handled within Genealis, only employees with a legitimate 'need to know' will have access to personal information.

With third parties

Genealis does not sell, rent, or trade your personal information. We may share personal information with third parties only in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our website and conducting business (e.g., Formspree for contact form processing, StatCounter for analytics)
• Legal Requirements: When required by law, regulation, or court order
• Business Protection: To protect our rights, privacy, safety, or property
• Consent: With your explicit consent for any other purpose
• Business Transactions: As part of a reorganization, divestiture, merger, or acquisition

Please be aware that such third parties may host information in the 'cloud' or may otherwise host personal information in the United States. By using Genealis's website, you consent to the storage and handling of your personal information in any country, including the United States.

Safeguards

Genealis will take commercially reasonable steps to protect your personal information. However, Genealis cannot guarantee that third parties will never be able to defeat our security measures or use your personal information for improper purposes.

Personal information in Genealis's possession

Genealis has implemented an information security program that contains administrative, physical, and technological security controls designed to reasonably safeguard your personal information against unauthorized access, disclosure, misuse, loss, or theft. These include:

• SSL encryption for data transmission
• Access controls and password protection
• Regular security assessments and updates
• Employee training on privacy protection
• Secure data storage and backup procedures

Personal information disclosed to third parties

Where personal information is disclosed by Genealis to third parties, such third parties are required to maintain the confidentiality and security of all personal information held by them on our behalf and to adhere to applicable privacy laws.

Retention

Genealis retains personal information for as long as required for the specific purpose for which it was collected or as otherwise required by law. Specifically:

• Contact form submissions and general inquiries: 1 year from last contact
• Employment applications: 2 years from application date
• Website analytics data: 26 months maximum
• Regulatory and compliance records: As required by applicable laws

Genealis destroys personal information in accordance with its record retention policies when the retention period expires.

Your Rights

Consent, refusal, and withdrawal

Genealis takes reasonable measures to ensure that the personal information we collect, process, and maintain is accurate, complete, current, and used only for the purpose(s) for which it was collected or authorized. Where required, Genealis will obtain your consent before it collects or uses your personal information.

You may withdraw your consent at any time subject to legal or contractual restrictions and reasonable notice. We may not be able to provide you with certain services should you withdraw your consent.

Access

You may gain access to your personal information that is handled by Genealis to review, correct, or delete it. To request such access, please contact our Privacy Officer using the contact information provided below.

Correction

If your personal information is out of date or incorrect, you may request that we update your personal information by contacting us using the information below.

Deletion

You may request deletion of your personal information, subject to our legal and regulatory obligations to retain certain information. We may not be able to delete your personal information where we are required to retain it by law or regulation.

Contact Our Privacy Officer

For inquiries regarding this privacy policy, to make a privacy complaint, or to exercise your privacy rights, you can reach our Privacy Officer by:

We will respond to your privacy-related inquiries within 30 days of receipt. You may also contact the Canadian Federal Privacy Commissioner at www.priv.gc.ca, or by calling 1-800-282-1376.

Amendments and Administration

Genealis may amend or update all or part of this privacy policy at its discretion to reflect new or different privacy practices. The amendments and updating of the privacy policy shall be applicable as soon as they are published on our website.

This privacy policy is administered by Genealis in accordance with the terms herein and in compliance with applicable laws, including PIPEDA and Ontario privacy legislation.