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 Addyi.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:

(1) the types of information the Company collects and how it collects this information;
(2) how the Company uses and may disclose the information it collects;
(3) the measures the Company takes to secure and protect the information it collects;
(4) how the Company secures and protects Personal Information; and
(5) 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 behalfs, 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 sent, 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 that 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 Addyi.com, please forward it immediately to info@searchlightpharma.ca 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 you 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 info@searchlightpharma.ca 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 a 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 roviders 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.