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PRIVACY POLICY

Privacy Policy Updated October 2024.


1. Our Commitment to Privacy

Syreon Corporation ("Syreon") recognizes the importance of maintaining and securing any personal data collected, in accordance with applicable laws, rules, and regulations. This policy describes how the company collects, uses, discloses, and protects personal data.

This Privacy Policy is subject to change without notice, so we recommend that you review it regularly. By using this site, you acknowledge that you have read and understand this Privacy Policy (as amended from time to time).

Syreon Corporation has adopted this Privacy Policy as a Canadian Company and is in compliance with the Canadian (PIPEDA and provincial and federal laws) and international privacy laws (Privacy laws in the USA and GDPR).


2. What's in this Privacy Policy?

This Privacy Policy covers the following topics:

  • Privacy Statement Updates
  • Definition of Terms
  • Personal Data We Collect
  • How We Use Your Personal Data
  • How We Share Your Personal Data
  • International Transfer and Storage of Information
  • Opting Out of Communications
  • How We Use Certain Technologies
  • Links to External Services
  • Retention of Personal Data
  • Protecting Your Personal Data
  • Your Rights
  • Withdrawaing Your Consent
  • How to Contact Us


3. Definition of Terms

By "Personal Data" we mean any information relating to an identifiable natural person or that, individually or in combination with other data, allows an individual to be identified.
By "Data Subject" we mean an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
By "Processing" or "Process" we mean all operations relating to personal data, including but not limited to collection, use, disclosure, sharing, deletion, etc.
By "Purpose of processing" we mean the main purpose of the processing of personal data. The data is collected for a well-defined and legitimate purpose and is not further processed in a way that is incompatible with this initial purpose.
By "Controller" we mean the natural or legal person that which, alone or jointly with others, determines the purposes and means of the processing of personal data.
By "Processor" we mean the natural or legal person that processes personal data on behalf of the controller, e.g., while providing a service or performance.


4. What Personal Data Do We Collect?

Syreon processes Personal Data which may be collected in two ways:

  • Directly from you, via forms, e-mails, activities, etc.
  • Indirectly from you, through the use of technological tools or third parties


5. Categories of Personal Data that We Collect

As a Controller:

  • Personal data: may be collected when an individual submits information through the Syreon website services, including registries such as the Syreon Career Centre or Syreon Investigator Registry, if an individual signs up to receive Syreon newsletters or whitepapers, if an individual participates in a clinical trial or research program, and/or if an individual contacts Syreon to inquire about services or request support regarding services. The types of personal data that may be collected from individuals may include name, home address, e-mail address, phone number, and account information. In the context of research, participant data is collected and processed in a de-identified format. Participants should contact their care-provider directly should they have any questions related to their data and exercising their data rights. Personal data is only retained for the length of time required to fulfill the purpose of its intended use.
  • Clinical Study Participants: Syreon does not hold directly personal data related to clinical study participants and individuals are reminded to contact their study investigator for any inquiries. In circumstances where Syreon processes personal data related to a clinical study, Clinical Study Participants will have received a separate privacy notice specific to the study, which will govern the use and management of Personal Data.
  • Usage and Analytics Data: We collect information such as time spent on the Online Platforms, pages visited, links clicked, language preferences, and pages that led or referred you to the Online Platforms. We collect this information to understand Online Platform usage, whether there are bugs, and to generally improve our Online Platforms. Please refer to section 9 for more information about cookies.
  • Newsletter and Marketing Data: If you subscribe to receive news from us on our Online Platforms, we collect your first and last names, e-mail, and organization. We also collect information through cookies to conduct targeted advertising on social media.
  • Employment: If you apply for an employment position, we collect information to evaluate your application, including your name, resume, and cover letter.
  • Social Media Data: Syreon may use social media as an extension of its presence on the web. Before engaging with us on social media platforms, we recommend that you read the privacy policies of these third-party service providers and those of any applications that you use to access them.

As a Processor:

Information obtained from third-party services:

  • Publicly accessible sources.
  • Social media platforms.


6. How Do We Use Your Personal Data?

Some of the purposes for which Syreon may collect, use, and disclose your Personal Data are:

  • To facilitate communication with you
  • To facilitate internal record keeping
  • Management of subscriptions to our newsletters and email alerts
  • Providing Customer Service by mail, telephone, email, or instant messaging
  • To manage and conduct research programs
  • Communication of information related to adverse drug reactions to regulatory authorities
  • Archiving of records for a reasonable length of time, for business administration and regulatory purposes
  • Processing job applications
  • Sending information on the modification or evolution of our services
  • Assisting in requests for access or correction to your records, or other data rights as stated under legislation
  • Data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing, and your experience
  • To comply with legal obligations (e.g., to maintain records for tax purposes, responding to court orders)
  • Other uses of information with individual's consent


7. Who Do We Share Your Personal Data With?

To administer services and operations, certain Personal Data may be shared with, or accessed by, authorized third-party service providers, such as e-commerce providers, payment card processers, telephone and technical support providers, data storage and processing service providers, and research and analytics providers. Your Personal Data will be provided to such third-party service providers only to enable the proper administration of such services and operations.

We may also share your Personal Data with service providers or outside third parties, including our data processors, to help conduct programs or administrative services, to cloud providers, or to conduct technical maintenance of our websites and other web platforms.

However, service Providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal data for their own marketing or other purposes. Third-party service providers are monitored through the Vendor Surveillance Program and must safeguard data in a manner consistent with data transfer agreements and applicable local and international legislation.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; and (f) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your Personal Data and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.


8. How Can You Opt-Out of Our Marketing Communications?

Syreon is committed to meeting the requirements of Canada’s Anti-Spam Legislation and international resolutions, including through any commercial electronic messages sent by Syreon to you. You may "Unsubscribe" from receiving any such applicable communications from us at any time and your electronic address will be removed from our databases.


9. How Do We Use Certain Technologies in Our Services?

What technologies do we use?

Our website uses cookie technology to make your use of our website more convenient. A cookie is a text file that enables our website to store information about your activities on the website, such as the date and time of visits, pages viewed, time spent, and websites visited just before and just after our website. Personal Data about your visits to, and use of, the website is used on an aggregate basis, meaning that it is used for statistical purposes to assist us in enhancing your online experience, or to evaluate the materials that we may carry on the website. We use Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to track and monitor the use of our services. This data is shared with other Google services.

Cookies will store your e-mail address, which is your unique identifier, so that on return visits, the website will be able to match you to your identity in the database. This is an opt-in feature that will only be made operational if you choose to do so.

Web beacons (also called "clear GIFs" or "pixel tags") are small strings of code that are placed in a web page or in an e-mail message and may be used in conjunction with cookies to track activity on our website. Since they are used in combination with cookies, if you disable cookies, the web beacons will only detect an anonymous website visit.

Do we use cookies for targeted advertising?

Our Online Platforms may also use services to advertise on third-party websites to previous visitors to our Online Platforms (e.g. Google AdWords, Facebook Conversion Pixel, and Twitter remarketing). Third-party vendors use cookies to serve ads based on someone’s past visits to our Online Platforms. For example, after browsing our website, you may receive related ads on your Facebook. This is known as interest-based advertising. In such a case, any data collected by Syreon will be used in accordance with this Privacy Policy and, for those other platforms, through their respective privacy policies.

How you can manage your cookie preferences

If you choose to disable cookies associated with our Online Platforms, this may affect your use of those platforms and your ability to access certain features. If you are looking for more information on cookies, you can refer to websites such as Cookie Central and All About Cookies.

You can also use WebChoices, which is a browser-based tool for opting out of interest-based advertising. WebChoices provides additional solutions and explanations to block and control cookies, as well as plug-ins to retain opt-out cookie preferences, even if you delete your cookies.
Depending on the browser that you are using, different instructions are applicable. In the list below, click on the browser that you use to find out more information:

You can opt out of making your activity on the website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Links to Other Sites

Our website may contain links to other websites, applications or digital products that are not operated by us. Syreon have no responsibility for, control over, or liability for those websites or internet resources, or their collection, use, and disclosure of your Personal Data. We recommend that you refer to the privacy policy and terms of use contained in any linked site that you choose to go to and that you familiarize yourself with that website’s terms and conditions of use.


10. Consent

Generally, we obtain your consent to Process Personal Data. Consent can be provided electronically or written form, or it can be implied where the purpose for collecting, using or disclosing your Personal Data would be considered obvious.

Consent may also be implied where we give you notice and a reasonable opportunity to opt-out of having your Personal Data being used, and you do not opt-out. Subject to certain exceptions, you can withhold your consent for Syreon to use your Personal Data in certain ways – and you can do so by contacting us. Your decision to withhold your consent to certain uses of Personal Data may restrict our ability to provide purposes, services or functionality.


11. How Long Do We Retain Your Personal Data?

We will retain your Personal Data only for as long as it is necessary to fulfill the identified purposes, or a legal or business purpose in accordance with this Privacy Policy or in accordance with any more specific agreement we make with you for the handling of that particular set of information.


12. International Transfers of Your Personal Data

Any Personal Information you provide to us may be transferred to or stored in a geographic region which imposes different privacy obligations than your country of origin. This may mean that your Personal Information may be sent to a country with less restrictive data protection laws than your own. Any such transfer will be conducted in compliance with applicable law and Personal Information may be subject to the local laws of the jurisdictions within which it is collected, used, transferred, disclosed and/or stored, and may be accessed by governmental and law enforcement authorities in those jurisdictions.


13. How Do We Protect Your Personal Data?

Syreon takes measures to protect the information against misuse, loss, disclosure, alteration or destruction by using a variety of commercially acceptable technologies and standards. In order to comply with the growing body of international data privacy laws and regulations, a number of operational programs are maintained, including Syreon Privacy Officer, Syreon Data Protection Officer, a Privacy Committee, and a Cybersecurity Committee, all tasked with monitoring the privacy landscape and enhancing technology and procedures related to securing data. Security safeguards are in place across all jurisdictions where data is collected, stored, or processed, and project development procedures incorporate Privacy by Design principles.


14. What Are Your Rights Regarding Your Personal Data?

Your privacy rights vary depending on where you reside. You may have the following consumer privacy rights under applicable state laws:

  • Right to Know: you may have the right to request information about the personal data we have collected about you and for what purpose.
  • Right to Access: you may have the right to request information about how we process your personal data and to obtain a copy of that personal data.
  • Right to Portability: you may have the right to receive your personal data, in a structured, commonly used, and machine-readable format and to have that information transmitted to another organization in certain circumstances.
  • Right to Deletion: you may have the right to request the deletion of your personal data that we have collected from you.
  • Right to Be Free from Discrimination: Syreon will not discriminate against you for exercising your consumer privacy rights.
  • Right to Opt-out of Sharing: you may have the right to opt out of Syreon sharing your personal data with third parties for some purposes, including sharing that may be defined as a sale under certain laws.
  • Right to Make Choices About Email Marketing: you may have the right to make choices about receiving email marketing.

Please keep in mind that we may not be able to honor all requests, such as if the information is required to process your payments or returns, to fulfill your order, or to comply with tax, audit, or other regulatory requirements.

California Residents

The California Consumer Privacy Act ("CCPA") grants California residents certain rights regarding the personal data that businesses have about them. These include (a) the right to know about personal data categories the business collected about you in the prior 12 months, the source of such information, the purpose for collecting the information and the specific information collected about you (this information is available in our Supplementary Disclosures; (b) the right to request access or deletion of your personal data, (c) the right to request correction of your personal data as well as (d) the right to direct a business to stop sharing your personal data. Syreon may be categorized as a "Service Provider" under the legislation in certain cases, such as in providing products and services to our customers. In other cases, Syreon may be categorized as a business, such as in our day to day operations. The categories of third parties to whom personal data is disclosed include advertisers and marketing partners and data analytics providers. The categories of information we may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data. To opt out, please send your request to us at the address listed in section 16 of this policy.

Colorado Consumers

The Colorado Privacy Act ("CPA") grants consumers that are residents of the State of Colorado certain rights provided by C.R.S. § 6-1-1-1306 regarding the personal data businesses have about them, subject to certain limitations. These rights are listed in more detail below, and at this time do not extend to individuals acting in commercial or employment contexts.

The Right of Access: Consumers have the right to confirm the processing of their personal data and to access their personal data and obtain a copy of it in a readily useable format (to the extent "technically feasible").
The Right to Correct Inaccuracies: Consumers may request that inaccuracies in their personal data are corrected, considering the nature of the data and the business’ purposes in using it.
The Right to Deletion: Consumers have the right to delete personal data concerning the consumer.
The Right to Data Portability: Consumers have the right to obtain a copy of their data from the controller (Syreon) in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity up to twice per year.
The Right to Opt-Out: Consumers have the right to opt out of several different uses of their personal data, including: targeted advertising, sale of their personal data, and profiling for the purpose of making decisions with legal or similarly significant effects concerning the consumers. To opt out, please send your request to us at the address listed in section 16 of this policy.

The categories of third parties to whom personal data is disclosed include advertisers and marketing partners and data analytics providers. The categories of information we may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data. To opt out, please send your request to us at the address listed in section 16 of this policy.

Colorado residents may appeal Syreon’s response to their requests by sending an email to privacy@syreon.com or by contacting us at our address noted above.

Connecticut Residents

The Connecticut Data Privacy Act or ("CTDPA") provides Connecticut residents with certain rights. At this time, it does not apply to employees or to business-to-business relationships. Connecticut residents the following rights:

The right to access personal data that a controller has collected about them.
The right to correct inaccuracies in their personal data.
The right to delete their personal data, including personal data that a controller collected through third parties.
The right to obtain a copy of their personal data in a portable and readily usable format that allows them to transfer the data to another controller with ease.
The right to opt-out of:

  • the sale of their personal data;
  • the processing of personal data for the purposes of targeted advertising; and
  • profiling that may have a legal or other significant impact.

A Connecticut resident may also designate another person to act on their behalf with respect to these rights.

The categories of third parties to whom personal data is disclosed include advertisers and marketing partners and data analytics providers. The categories of information we may share with such parties may include device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history; location information, such as city; and inference data. To opt out, please send your request to us at the address listed in section 16 of this policy.

Virginia Consumers

The Virginia Consumer Data Protection Act ("VCDPA") grants consumers that are residents of the Commonwealth of Virginia certain rights regarding the personal data businesses have about them, subject to certain limitations. These rights are listed in more detail below, and at this time do not extend to individuals acting in commercial or employment contexts.

The Right to Know: Consumers have the right to know whether or not a business processes their personal data;
The Right of Access: Consumers have the right to access their personal data, and obtain a copy of it in a readily useable format (to the extent "technically feasible");
The Right to Correct Inaccuracies: Consumers may request that inaccuracies in their personal data are corrected, considering the nature of the data and the business’ purposes in using it;
The Right to Data Portability: Consumers have the right to obtain a copy of their data from the controller (Syreon) in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller;
The Right to Opt-Out: Consumers have the right to opt out of several different uses of their personal data, including: targeted advertising, sale of their personal data and profiling for the purpose of making decisions with legal or similarly significant effects concerning the consumers. To opt out of targeted advertising online, please adjust your cookies settings to reject marketing cookies as described in Syreon’s Cookie Notice. For other opt-outs or requests, please contact us at privacy@syreon.com or write to us at the address listed in section 16 of this policy.


15. Roles and Responsibilities

Your Role

We expect that you will provide us with accurate and up to date Personal Data as may be required for your participation in one of the Purposes. We also expect that you will otherwise follow the expectations set out in this Policy, or to notify us of your questions or concerns as soon as possible as indicated within this Policy. We also expect that you will provide us with accurate and up-to-date information related to any concerns that you may have regarding our data management practices as well as information that will help us determine issues of privacy compliance.

Our Role

We will take all reasonable steps to ensure that we comply with our obligations under this Policy. We will also take reasonable steps to ensure that we notify you should this Policy be updated or the circumstances for which we are using your Personal Data are expected to change.


16. Questions or Concerns

Questions or concerns regarding our collection, use, and disclosure of your Personal Data or about this Privacy Policy, can be directed to our Privacy Officer at the following e-mail address: privacy@syreon.com or at the following postal address:

Privacy Officer
Syreon Corporation
220—1401 West 8th Ave
Vancouver, BC
V6H 1C9   Canada

Privacy Policy Effective Date: 12 December 2024.