Privacy policy

REPLICOR INC.
CORPORATE PRIVACY POLICY

OVERVIEW

At Replicor Inc. (“Replicor”), respecting privacy is an important part of our commitment to partners, collaborators and the general public.

When you provide personal information to us, including your email address, you can be confident that any personal information that you share with us will stay with us.

The Replicor Privacy Policy is a statement of principles and guidelines describing the level of protection of personal information provided by Replicor to the general public. The objective of the Replicor Privacy Policy is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).

Replicor will continue to review its Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.

If you have any concerns about how your privacy is protected at Replicor, please contact our Privacy Officer by e-mail at info@replicor.com, or by mail at:

6100 Royalmount Avenue
Montreal, Quebec
Canada H4P 2R2

Attention: Privacy Officer

THE DETAILED REPLICOR CORPORATE PRIVACY POLICY

SCOPE AND APPLICATION

The ten principles that form the basis of The Replicor Privacy Policy are interrelated and Replicor shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in The Replicor Privacy Policy has been drafted to reflect personal information issues specific to Replicor.

The scope and application of The Replicor Privacy Policy are as follows:

• The Replicor Privacy Policy applies to personal information collected, used, or disclosed by Replicor in the course of commercial activities.

• The Replicor Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.

• The Replicor Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Replicor:

(a) non-personally identifiable information;
(b) the name, title, business address and/or telephone number of an employee of an organization;
(c) other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).

– The application of The Replicor Privacy Policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted thereunder, and any other applicable legislation or regulation including the Personal Information Protection Act (British Columbia).

DEFINITIONS

collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Replicor. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

disclosure: Making personal information available to a third party.

employee: An employee of or independent contractor to Replicor.

personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.
third party: An individual or organization outside of Replicor.

use: The treatment, handling, and management of personal information by and within Replicor or by a third party with the knowledge and approval of Replicor.
THE TEN PRINCIPLES OF PRIVACY
PRINCIPLE 1 – ACCOUNTABILITY

Replicor is responsible for personal information under its control and shall designate one or more persons who are accountable for Replicor’s compliance with the following principles.

Responsibility for compliance with the provisions of the Replicor Privacy Policy rests with the Replicor Privacy Officer. The Replicor Privacy Officer can be contacted by e-mail at info@replicor.com, or by mail at:

6100 Royalmount Avenue
Montreal, Quebec
Canada H4P 2R2

Attention: Privacy Officer

Other individuals within Replicor may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

Replicor is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.
PRINCIPLE 2 – IDENTIFYING PURPOSES FOR COLLECTION OF PERSONAL INFORMATION

Replicor shall identify the purposes for which personal information is collected at or before the time the information is collected.

Replicor collects personal information from the public only for the following purposes:

(a) to conduct scientific research;

(b) to provide information ot the public by way of newsletters and email notices;

(c) to meet legal and regulatory requirements.

Further reference to “identified purposes” mean the purposes identified in this Principle.

Replicor shall specify orally, electronically or in writing the identified purposes at or before the time personal information is collected. When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the provider of the personal information will be acquired before the information will be used or disclosed for the new purpose.

Replicor may provide third parties with information in aggregate form. In aggregate form it is impossible to identify an individual’s personal information.
PRINCIPLE 3 – OBTAINING CONSENT FOR COLLECTION, USE OR DISCLOSURE OF PERSONAL INFORMATION

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Generally, Replicor shall seek consent to use and disclose personal information at the same time it collects the information. However, Replicor may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose. In determining the appropriate form of consent, Replicor shall take into account the sensitivity of the personal information and the reasonable expectations of the individuals.
PRINCIPLE 4 – LIMITING COLLECTION OF PERSONAL INFORMATION

Replicor shall limit the collection of personal information to that which is necessary for the purposes identified by Replicor. Replicor shall collect personal information by fair and lawful means.
PRINCIPLE 5 – LIMITING USE, DISCLOSURE, AND RETENTION OF PERSONAL INFORMATION

Replicor shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Replicor may disclose an individual’s personal information to:

(a) a third party engaged by Replicor to perform functions on its behalf;
(b) a public authority or agent of a public authority if, in the reasonable judgment of Replicor, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
(c) a third party or parties, where the individual consents to such disclosure or disclosure is required or permitted by law.

Only Replicor’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about individuals.

Replicor shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where an individual may have to be re-contacted for purposes of clarifying information provided, Replicor shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

Replicor shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
PRINCIPLE 6 – ACCURACY OF PERSONAL INFORMATION

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Replicor shall update personal information about individuals and employees as necessary to fulfill the identified purposes or upon notification by the individual.
PRINCIPLE 7 – SECURITY SAFEGUARDS

Replicor shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Replicor shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

Replicor shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of Replicor’s employees with access to personal information shall be required to respect the confidentiality of that information.

PRINCIPLE 8 – OPENNESS CONCERNING POLICIES AND PROCEDURES

Replicor shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

Replicor shall make information about its policies and procedures easy to understand, including:

(a) the title and address of the person or persons accountable for Replicor’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;
(b) the means of gaining access to personal information held by Replicor;
(c) a description of the type of personal information held by Replicor, including a general account of its use; and
(d) a description of what personal information is made available to related organizations (e.g. subsidiaries).
PRINCIPLE 9 – INDIVIDUAL ACCESS TO PERSONAL INFORMATION

Upon request, Replicor shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Privacy Officer, Replicor will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information

In certain situations, Replicor may not be able to provide access to all the personal information that it holds about an individual. For example, Replicor may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Replicor may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, an individual may be required to provide sufficient identification information to permit Replicor to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

Replicor shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file.

Where appropriate, Replicor shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
Respondents and employees can obtain information or seek access to their individual files by contacting the Replicor Privacy Officer.
PRINCIPLE 10 – CHALLENGING COMPLIANCE

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Replicor’s compliance with the Replicor Privacy Policy.

Replicor shall maintain procedures for addressing and responding to all inquiries or complaints from individuals regarding Replicor’s handling of personal information.

Replicor shall, on written request, inform individuals about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with the Replicor Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

Replicor shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, Replicor shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The individual shall be informed of the outcome of the investigation regarding his or her complaint.
ADDITIONAL INFORMATION

For more information regarding the Replicor Privacy Policy, please contact the Replicor Privacy Officer by e-mail at info@replicor.com, or by mail at:

6100 Royalmount Avenue
Montreal, Quebec
Canada H4P 2R2

Attention: Privacy Officer

Please visit the Privacy Commissioner of Canada’s website at www.privcom.gc.ca.