Politique de confidentialité

PRIVACY POLICY

Last Updated: January 7, 2025

Milestone Pharmaceuticals USA, Inc., along with our subsidiaries and affiliates, (collectively, “Milestone,” “we,” “us,” and “our”) are committed to protecting the privacy and security of your personal information. This privacy policy (“Privacy Policy” or “Policy”) describes how we process the personal information we collect in the course of providing our products and services (the “Services”), which includes when you visit our website www.milestonepharma.com or any other site that posts this policy (our “Sites”), apply for a job with us, or otherwise interact with us directly or indirectly. Residents of Washington and Nevada, please also see our Consumer Health Data Privacy Policy.

Please note that this Policy does not apply to third party websites, including any third-party sites that we may include links to on our Sites. Please review the privacy policy of any website you visit to determine how the operator handles personal information.

  1. What is “Personal Information”?
  2. What Personal Information do we collect and from what sources?
  3. Do we use cookies and other tracking technologies?
  4. How do we use Personal Information?
  5. How do we disclose Personal Information?
  6. How do we safeguard Personal Information?
  7. How long do we retain Personal Information?
  8. Do we collect Personal Information about children?
  9. What are your choices with respect to your Personal Information?
  10. What are your rights with respect to your Personal Information?
  11. What additional information do California residents need to know?
  12. What additional information do international residents need to know?
  13. How will you know about updates to this Policy?
  14. How can you contact us?

1. What is “Personal Information”?

“Personal Information” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

2. What Personal Information do we collect and from what sources?

The Personal Information we collect about you depends on your relationship with us. We collect Personal Information directly from individuals, from third parties that provide your information with your authorization or otherwise on your behalf, or from other sources such as social media or public databases. The Personal Information we collect includes the following:

  • Contact details such as name, email address, phone number, and address
  • Professional information such as employer, job title, NPI, business contact information, education or employment history
  • Insurance information such as insurance policy number or health insurance information
  • Commercial information such as samples, products or services purchased, obtained, or considered
  • Payment and billing information
  • Sensitive Personal Information such as health data
  • Inferences drawn from any of the information listed above to create a profile about you reflecting your preferences, characteristics, behavior, and attitudes

We may also collect Personal Information automatically using various tracking technologies on our Sites. The information collected by these tracking technologies may include IP address and geolocation information as well as information about your device and web browser. See further information in the section below.

3. Do we use cookies and other tracking technologies?

Like most websites, our Sites use cookies and other tracking technologies. Cookies are small text files that are transferred to your computer by a website. All of our Sites use the following types of cookies:

  • Necessary Cookies: These cookies are required for the Sites to function and cannot be switched off. They are usually only set in response to your request for services, such as setting your privacy preferences or filling in forms. You can set your browser to block or alert you about these cookies, but if you do so, some parts of the Sites may not work.
  • Functional Cookies: These cookies enable the Sites to provide enhanced functionality and personalization by remembering certain user preferences.

Additionally, some of our Sites may use either or both of the following types of cookies:

  • Analytics Cookies: These cookies allow us to count visits and traffic sources to our Sites so we can measure and improve the performance of our Sites. They help us to know which pages are the most and least popular and see how visitors move around the Sites. We may also use these types of cookies to gauge how you interact with our marketing emails.
  • Advertising Cookies: These cookies collect information about your browsing activities to understand your interests in order to display advertising that may be relevant to you, based on your online activity. Third-party advertising partners may use these cookies to collect information about you and show you relevant ads on other sites. If you do not allow these cookies, you may still receive advertising, but it may be less relevant to you.

Some internet browsers have “Do Not Track” or “DNT” features which, when turned on, send a signal to a website that the individual visiting the website does not wish to be tracked. Such browser features and industry standards are not uniform, so our Sites do not respond to DNT signals, but you can control your cookie preferences in the settings of your Internet browser. Please note that if you block or reject cookies and similar technologies on our Sites, functionality of the Sites may be limited.

Please note that we may engage third party analytics and advertising partners, including but not limited to, Google Analytics, who may place their own cookies and tracking technologies on our Sites. The user activity information collected by these tracking technologies may be stored and used by these partners. You can opt-out of Google Analytics by downloading Google’s Opt-Out Browser Add-on.

4. How do we use Personal Information?

We process Personal Information for a variety of purposes, including to:

  • Respond to your questions and communicate with customers and prospective customers
  • Operate, manage, and maintain our business and maintain records
  • Provide, develop, improve, and maintain our products and Services
  • Analyze and better understand consumers’ needs, preferences, and interests and conduct internal business analysis and research
  • Advertise and promote our products and services, including by contacting you regarding products, services, and topics that may be of interest to you
  • Engage with current and prospective advertisers, advocacy organizations, service providers, and third parties
  • Undertake quality and safety assurance measures and conduct risk and security controls and monitoring
  • Detect and prevent fraud and perform identity verification
  • Perform accounting, audit, and other internal functions, such as internal investigations
  • Evaluate job applicants for employment
  • Comply with law, legal process, and internal policies
  • Exercise and defend legal claims
  • For any other purpose you may agree to at or before the time the Personal Information is collected

We may also aggregate and/or anonymize personal information and analyze that data for statistical or any other purposes permitted by law.

5. How do we disclose Personal Information?

We disclose Personal Information in the following ways:

  • To affiliates and subsidiaries within our corporate family.
  • To service providers who process Personal Information on our behalf, including service providers who provide data hosting, information technology support, email hosting, marketing, and analytics services, and other services for the operation of our business.
  • To third-party marketing, advertising, and analytics companies, who may process Personal Information for their own purposes.
  • To certain third parties with your consent or direction. These parties may include health care providers, pharmacies, or insurers.
  • To other third parties to protect our rights, defend or pursue a legal claim, or investigate or prosecute illegal activities.
  • To government or judicial authorities or agencies to comply with a subpoena, court order, governmental inquiry, legal process, legal obligation, or to protect the rights, property, or safety of other users or the public. This includes complying with adverse event reporting obligations.
  • To a successor entity or purchaser upon a merger, consolidation, or other corporate reorganization in which we participate, or pursuant to a financing arrangement.

6. How do we safeguard Personal Information?

We maintain organizational, technical, and administrative measures designed to protect Personal Information against unauthorized or illegal access, destruction, use, loss, modification, or disclosure. We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of Personal Information, however, no data transmission or storage system is guaranteed to be 100% secure in all circumstances.

7. How long do we retain Personal Information?

We retain Personal Information we collect for the time period required to fulfill the legitimate business purposes for which it was collected and to engage in the use and disclosure practices outlined in this Privacy Policy, unless a different retention period is required by applicable law, or otherwise to fulfill a legal obligation or protect our legal rights.

8. Do we collect Personal Information about children?

Our Services are not intended for children under the age of 18 years old and we do not knowingly collect such information. In the event we learn that we have collected Personal Information from a child under age 18, we will delete it in accordance with applicable law. If you believe that we might have Personal Information from or about a child under 18, please contact us.

9. What are your choices with respect to your Personal Information?

You may opt out of receiving email marketing communications from us by clicking the unsubscribe link included in our emails or contacting us. Please note that we may still send you transactional and administrative emails even if you opt out of marketing communications.

You may opt out of receiving automated text message marketing communications from us by replying “STOP” to the message or contacting us. Please note that we may still send you transactional and administrative text messages even if you opt-out of marketing communications.

Based on where you live, you may have additional rights regarding your Personal Information; see Section 10 below.

10. What are your rights with respect to your Personal Information?

Depending on your jurisdiction of residence, you may have some or all of the privacy rights listed below with respect to the Personal Information we maintain about you. Depending on the jurisdiction, these rights may apply specifically to consumer health data. Please note that these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

  • Right to Confirm / Access / Know. You may have the right to request access to Personal Information that we hold about you, including details relating to the ways in which we collect, use, and share your information. Residents of California have the right to know the categories of Personal Information we have collected about them, the categories of sources from which the Personal Information is collected, the categories of Personal Information sold, shared, or disclosed, the business or commercial purpose for selling, sharing, or disclosing the Personal Information, and the categories of third parties to whom we have sold, shared, or disclosed their Personal Information. California’s “Shine the Light” law also permits users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.
  • Right to Delete. You may have the right to request that we delete Personal Information we maintain about you.
  • Right to Correct. You may have the right to request that we correct inaccurate Personal Information we maintain about you.
  • Right of Portability. You may have the right to receive a copy of the Personal Information we hold about you and to request that we transfer it to a third party.
  • Right to Withdraw Consent. You may have the right to withdraw your consent to processing of your Personal Information.
  • Right to Opt-Out. You may have the right to opt-out of certain uses of your Personal Information such as for (i) online targeted advertising, (ii) “sale” or “sharing” for cross-context behavioral advertising, or (iii) profiling or automated decision-making activities that result in a legal or similarly significant effect on you. You can opt-out of uses (i) and (ii) by adjusting your cookies settings to reject analytics and advertising cookies. Additionally, if you visit our Sites with the Global Privacy Control opt-out preference signal enabled, if required by law, we will treat that signal as a request to opt-out of « sale, » « sharing, » or targeted advertising. Please note your request may apply only to the browser or device from which you submit the request. Learn more about the Global Privacy Control here.
  • Right to Appeal. You may have a right to appeal our decision if we decline to process your request in part or in full. You can do so by replying directly to our denial. If you are not satisfied with our response to your appeal, you may contact your state Attorney General.

Requests to exercise these rights may be made using the contact information listed at the end of this Policy, or as otherwise described in this section. Only you, or as permitted by law, a person that you authorize to act on your behalf, may make a request related to your Personal Information. For certain requests, we must verify your request before we can fulfill it. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected Personal Information or that the requestor is authorized to act on your behalf. We will not discriminate against you for exercising your privacy rights.

11. What additional information do California residents need to know?

This section provides additional disclosures for residents of California, as required by the California Consumer Privacy Act (“CCPA”). Please remember that the information we collect varies based on our relationship with you and note that certain Personal Information or activities are not reflected in this section because they are exempt from the CCPA.

CCPA Categories of Personal Information We Collect and How and Why We Collect Them

We collect the following categories of Personal Information about California consumers. This information may be, or have been, collected directly from you, automatically when you use our Services, or from third parties.

  • Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, or other similar identifiers.
  • Personal Information described in Cal. Civ. Code § 1798.80(e), including name, signature, address, telephone number, education, employment, employment history, bank account information, credit card number, debit card number, or other financial information.
  • Characteristics of protected classifications under California or federal law, including age and date of birth, gender, medical condition, or disability.
  • Commercial information, including records of samples, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, information about a consumer’s interaction with our Sites.
  • Geolocation data, including location data inferred from your device IP address.
  • Audio, electronic, visual, thermal, olfactory, or similar information, including photographs and videos, and audio recordings.
  • Professional or employment-related information, including business contact information as well as information collected during the hiring process.
  • Non-public education information, including transcripts or other information collected during the hiring process.
  • Inferences used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Sensitive Personal Information, including health data; account log-credentials; and citizenship or immigration status. Note that citizenship and immigration status is collected in the job applicant context. To the extent we collect sensitive personal information, we do not use it to infer characteristics about individuals.We use, and have used, the Personal Information we collect for the purposes set forth in Section 4 above.

CCPA Categories of Personal Information Disclosed

We disclose all of the above categories of Personal Information as set forth in Section 5 above. Note that these disclosures are either made to a service provider for a business purpose under the CCPA or pursuant to the individual’s consent.

CCPA Categories of Personal Information Sold or Shared

Under the CCPA, a “sale” of Personal Information does not necessarily involve an exchange of money. Instead, a sale also includes disclosures of Personal Information to third parties who may use the information for their own purposes, such as analytics and advertising cookie providers. Similarly, under California law, “sharing” Personal Information refers to disclosing of Personal Information to third parties for cross-context behavioral advertising. Per these definitions, we sell and share the following categories of Personal Information to third party analytics and advertising partners:

  • Identifiers
  • Personal Information described in Cal. Civ. Code § 1798.80(e)
  • Internet or other electronic network activity information
  • Geolocation data
  • Inferences

Privacy Rights for California Residents Relating to Your Personal Information

Please refer to Section 10 above for information regarding the rights you have with respect to your Personal Information and how to exercise them.

12. What additional information do international residents need to know?

Milestone is located in the U.S. and Canada. By visiting the Sites or using the Services, you acknowledge and agree that your Personal Information may be processed as set forth in this Privacy Policy and it may be processed in a country other than your country of residence, where laws regarding processing of Personal Information may be less stringent than the laws in your country.

13. How will you know about updates to this Policy?

This Policy is subject to change at our discretion, which will be indicated by updating the “Last Updated” date at the top of the Policy. Your continued use of the Services after any update to this Policy will constitute your acceptance of any changes.

14. How can you contact us?

If you have questions about anything contained in this Privacy Policy, including how your Personal Information is used, or if you would like to exercise your privacy choices or rights, please contact us at:

Milestone Pharmaceuticals, Inc.
1111 Dr. Frederik-Philips Blvd, Suite 420
Montreal, (Quebec), H4M 2X6 Canada
privacy@milestonepharma.com