Privacy Policy
To Help Provide Better Protection
Mise à jour : Février 2025
Contact Us
If you have any questions about the application of these Terms of Use, feel free to contact the individual responsible for the protection of personal information at Mantra Pharma Inc. (the “Privacy Officer”) using the contact information below:
Chief Legal Counsel
1000 Du Lux Street, Suite 201
Brossard, Quebec, J4Y 0E3
450-678-7088
confidentialite@mantrapharma.ca
Denta.ca Website
The website https://denta.ca/ is the exclusive property of Mantra and was primarily designed to provide information about the Denta product line, offered by Mantra in Canada.
Context
Did you know that in Quebec, the Civil Code of Quebec, the Charter of Human Rights and Freedoms, and the Act Respecting the Protection of Personal Information in the Private Sector (the “Act”), among other laws, guarantee your right to privacy?
As part of its mission and commitment to its values, Mantra Pharma Inc. and its affiliated companies (collectively “Mantra”, “we”, “us”, or “our”) place a high priority on respecting your privacy and the confidentiality of your personal information. This Privacy Policy outlines Mantra’s rules and practices in a user-friendly Q&A format.
If you do not agree to these Terms of Use, please refrain from using the Website. If you do not want Mantra to collect your personal information in accordance with its Privacy Policy and Terms of Use, we recommend that you avoid submitting such information or using our Website.
Please note that in such cases, we may be unable to offer you certain products or services. Feel free to contact us to discuss this further.
Definitions
Q. What is 'Personal Information'?
A. Any information that allows Mantra to identify you, directly or indirectly.
This includes, for example, your name, address, phone number, email address, date of birth, medical information, details of your current or past use of Mantra’s products and services, credit card information, order history (if applicable), Mantra user ID and password, as well as all data collected through the Mantra website or related to the delivery of products or services.
Q. What is 'Sensitive Personal Information'?
A. Information for which there is a high reasonable expectation of privacy. Mantra is committed to obtaining your express consent for such data.
Examples include financial, genetic, or biometric data; information related to your health, sexual life, or sexual orientation; religious or philosophical beliefs; or racial or ethnic origin.
Q. What is 'Computerized Personal Information'?
A. Computerized Personal Information refers to Personal Information that has been collected in a computerized form, meaning it is organized and structured using information technology, and obtained directly or indirectly from you only, not from a public body or a business.
This includes, for example, data such as your name, email address, financial information, phone number, work-related information, activity logs, purchase history, as well as your search data; all collected in computerized form. Personal Information stored or collected in physical form, such as a printed form or a handwritten note, is not considered computerized Personal Information.
Q. Is professional contact information considered Personal Information?
A. No. Your name, title, work address, phone number, or fax number, when used for professional purposes, are not subject to this Privacy Policy.
Q. What is the 'life cycle' of Personal Information?
A. It refers to the collection, use, disclosure, retention, and destruction of personal Information. Mantra is responsible for protecting your data throughout this entire life cycle.
Q. Who does Mantra’s Privacy Policy apply to?
A. To all clients, consumers, agents, partners, suppliers, patients, and individuals who have done business with Mantra, or participated in clinical trials or studies in the past, present, or future ('you', 'your’, ‘yours’).
Collection
Q. Whose Personal Information does Mantra collect?
A. Mantra may collect personal information from its clients, employees, consumers, agents, partners, suppliers, patients, and individuals who have participated in clinical studies or trials.
Q. Does Mantra collect Personal Information from minors?
A. Mantra does not knowingly collect information about minors. If such information is inadvertently collected, Mantra is committed to complying with all applicable legal and regulatory requirements.
Q. Does Mantra collect all types of Personal Information?
A. No. Mantra must have a serious and legitimate interest in collecting Personal Information and commits to using lawful means and limiting collection to what is necessary.
Examples of purposes for collecting Personal Information:
(i) To conduct business activities, manage business relationships, handle administration, meet contractual obligations, and protect commercial interests (e.g., during recruitment);
(ii) To provide products or services (e.g., online orders, service requests, clinical study participation, pharmacovigilance inquiries, or communications through website, computer, or phone);
(iii) To communicate with you for authorized or agreed-upon purposes.
Use
Q. For what purposes does Mantra use your Personal Information?
A. Mantra may use your Personal Information for various legitimate purposes, including:
- To carry out pharmacovigilance activities
- To respond to inquiries about Mantra's products and services and to assist customers
- To improve and optimize your experience on Mantra’s website
- To maintain, secure, and analyze its IT systems, databases, and software
- To gather insights on products and services and to support development
- For research and development purposes
- To compile data related to clinical trials
- For recruitment
- To reorganize or modify the structure of the company
- To collect outstanding payments
- To send information on products and services
- For marketing and business development purposes
- To distribute promotional materials, newsletters, offers, and updates
- To comply with legal, regulatory, or risk management obligations
- To handle complaints
- To process data obtained through its digital systems
Q. Which Mantra employees or third parties may access your Personal Information?
A. Only Mantra representatives, agents, advisors, delegates, and employees who have a legitimate need to know your personal information and who are bound by confidentiality agreements may access it as part of their job duties.
Disclosure
Q. To whom may Mantra disclose your Personal Information?
A. Personal Information collected by Mantra may be disclosed to:
- Any affiliated company of Mantra
- Third-party service providers under contract with Mantra (with data protection obligations)
- Your authorized representative
- Government authorities such as the Commission d’accès à l’information or as required by judicial or governmental procedures
Q. Does Mantra require your consent before disclosing Personal Information to third parties?
A. Yes, except where exemptions are provided by law.
Q. Can you provide concrete examples?
A. Examples include service providers who manage Mantra’s website, IT systems, cloud services, or consultants in marketing or pharmacovigilance.
Q. What safeguards are in place before disclosing your Information to third parties?
A. Mantra ensures that any third party maintains confidentiality and uses your personal information solely to provide services to Mantra, in accordance with this Privacy Policy. Mantra also requires a level of protection equal to that provided under this Policy.
Q. Does Mantra share named lists containing Personal Information with third parties?
A. No. If Mantra ever wishes to do so, it will obtain your express consent unless otherwise permitted by law.
Q. Does Mantra use your Personal Information for commercial or philanthropic solicitation?
A. No. At no time does Mantra engage in the business of compiling files on others or preparing and disclosing credit reports to third parties regarding an individual’s character, reputation, or creditworthiness. If Mantra wishes to use Personal Information for commercial or philanthropic prospecting purposes, we commit to explicitly informing you, and you will then have the option to withdraw your consent.
Retention
Q. How long does Mantra retain your Personal Information?
A. Mantra retains personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.
For more details about specific retention periods, you can contact us using the information provided above.
Q. Is all Personal Information retained?
A. Mantra is obligated to securely retain all Personal Information it collects, regardless of the format or whether the Information is actively being used.
Q. Does Mantra ensure the quality of the Personal Information it holds?
A. Yes. Mantra ensures that the Personal Information it holds is accurate and up to date at the time of use. By using Mantra’s services or products, you agree to provide accurate and current information and to inform us of any changes in a timely manner.
Destruction
Q. When does the life cycle of Personal Information end?
A. The lifecycle of Personal Information ends once the purpose for which it was collected has been fulfilled, followed by its destruction. Mantra must therefore destroy or anonymize Personal Information securely, in accordance with generally recognized best practices, as soon as the purpose for which it was collected has been fulfilled, subject to any timeframes provided by law or regulations.
Q. Does destruction apply to both paper and digital records?
A. Yes. Paper documents must be shredded, blacked out, or securely discarded. When hardware (e.g., computers, tablets, USB keys, servers, external drives) reaches the end of its life, Mantra ensures that all Personal Data is securely erased.
Q. What is the applicable destruction timeframe?
A. Certain laws and regulations may prescribe minimum retention periods. Mantra has established a retention schedule to justify the duration of Personal Information retention.
Q. Must Personal Information always be destroyed?
A. No. In accordance with the law, Mantra may instead choose to anonymize the data, rendering it unidentifiable.
Q. What is 'anonymization'?
A. Anonymization means that the information can no longer identify you, directly or indirectly, in an irreversible way. Mantra adheres to clear rules when anonymizing data.
Consent
Q. Does Mantra require your consent throughout the entire data life cycle?
A. Yes. Mantra is committed to collecting, using, disclosing, retaining, and destroying your Personal Information only with your consent or as permitted by law. Your consent must be clear, free, and informed.
Q. Does Mantra collect your Personal Information directly from you only, or can it also collect it from a third party?
A. Whenever possible, Mantra will obtain consent directly from you. However, if you provide us with Personal Information about another person, you acknowledge that you have obtained that person's consent before sharing the information with us.
Q. With your consent, can all of your Personal Information always be collected, used, or disclosed by Mantra?
A. No. Mantra must have a serious and legitimate interest. Only the Personal Information that is necessary may be collected, used, or disclosed. Therefore, whenever possible, Mantra will request your authorization before collecting or using your Personal Information by informing you of the type of information collected and how it will be used.
Q. What does 'your consent' mean in practice?
A. When consent is required, Mantra must inform you of:
- Who is collecting your personal information
- The purposes of collection
- The methods of collection
- Your rights to access, portability, and rectification
- Your right to withdraw consent
- The data retention period
Q. Is consent always required?
A. No, there are exceptions. In some cases, it may not be necessary or possible to obtain your consent before collecting or using your Personal Information.
Q. What are those exceptions?
A. Your Personal Information may be used for purposes other than those for which it was originally collected, without your consent, in the following situations:
- The Personal Information is clearly used for your benefit (for example, by interacting with Mantra, whether by accessing its website or communicating directly with Mantra by phone, email, or in person, you agree that your Personal Information is subject to the terms and conditions set out in this Privacy Policy, including the Website Terms of Use);
- The Personal Information is used for purposes that are compatible with those for which it was originally collected;
- In cases of fraud, or to enhance protection or security measures;
- The Personal Information is used for study, research, or statistical purposes and has been de-identified.
A. Your Personal Information may be disclosed to third parties without your consent in the following situations:
- To you or to a related person following an approved access request;
- To a service provider who has entered into a written agreement with Mantra (under this agreement, the provider is required to protect your Personal Information);
- At the request of a government agent with a warrant, a Crown prosecutor, your lawyer, etc.;
- If Mantra has reasonable grounds to believe that your safety is at risk or that an imminent danger of death or serious injury (including suicide) can be prevented;
- If the disclosure of your Personal Information is necessary for a business transaction;
- Upon written request from a person or organization wishing to use Personal Information for study, research, or statistical purposes;
- At the request of a regulatory body, law enforcement, or other authorities with enforcement powers;
- To any other organization or individual as required by Quebec law.
Refusal or Withdrawal of Consent
Q. Can you refuse or withdraw your consent to the collection, use, disclosure, or retention of your Personal Information?
A. Yes, you may refuse to give your consent or withdraw your consent at any time.
Q. How do you proceed?
A. You may provide reasonable notice either in writing or verbally, addressed to the Person responsible for this Privacy Policy at Mantra.
Q. Will there be any consequences to such a refusal or withdrawal?
A. Yes. You should understand that without your consent to the collection, use, and retention of your Personal Information, it may become difficult for Mantra to provide you with services. Depending on the situation, we will inform you of the consequences of such a withdrawal. However, Mantra cannot refuse to offer you a good, service, or employment if you refuse to provide a Personal Information item, except where permitted by law.
Q. Can Mantra override your consent?
A. Yes, in specific cases, Mantra may override your consent if:
(i) the collection is necessary to conclude or deliver the service;
(ii) the collection is authorized by law; or
(iii) there are reasonable grounds to believe that your refusal is not lawful.
Access, Portability, and Rectification Requests
Q. Who owns the personal information contained in Mantra's records?
A. Your personal information belongs to you!
Q. Can you obtain a paper copy of your Personal Information?
A. Yes. You may request a copy of your Personal Information at any time, free of charge.
Q. Can you obtain a digital copy of your Personal Information?
A. Yes. As of 2024, you have the right to data portability. This means you can request that your personal information be provided to you, or to an organization of your choice, in a digital format.
Q. Is all Personal Information eligible for digital portability?
A. No. Only computerized personal information that was originally collected from you in digital form is eligible to be shared in a portable digital format.
Q. What format will the digital data be provided in?
A. Your data will be provided in a readable format using a "structured and commonly used technological format." While the law does not define this precisely, formats such as CSV, XML, JSON, ODT, and ODS, including metadata, are recommended. Image files and PDFs are generally discouraged.
Q. Can you request a correction to your Personal Information?
A. Yes. Subject to certain legal exceptions, you may request that Mantra correct any Personal Information that is inaccurate, incomplete, misleading, or was collected or retained contrary to applicable laws.
Q. How do you submit a request for access, portability, or rectification?
A. Requests must be made in writing to the Privacy Officer listed in this Privacy Policy. You may use the forms provided by the Commission d’accès à l’information, available at: https://www.cai.gouv.qc.ca/commission-acces-information/formulaires-lettres-types
Q. What is the response time for such requests?
A. Mantra will handle requests diligently and within the legal timeframe (generally 30 days). If you have a disability, reasonable accommodations can be arranged to support the exercise of your rights.
Q. Can your request for access, portability, or correction be refused?
A. Yes. Mantra may temporarily refuse a request in certain situations, including:
(i) If the information relates to your health and, in the opinion of a healthcare professional, disclosure could cause serious harm;
(ii) If the data is necessary to fulfill legal obligations;
(iii) If disclosure would seriously impact another individual;
(iv) If it would interfere with ongoing legal proceedings or investigations;
(v) If the request is made by a minor under 14 or someone legally incapable, without proper authorization;
(vi) If the data requested for portability was derived or inferred from other digital information;
(vii)
If the request is repetitive, abusive, or non-compliant;
(viii)
If responding to the request would present serious practical difficulties (e.g., cost, complexity).
If, for any reason, Mantra refuses to comply with your request, it will notify you in writing, stating the reasons for the refusal and informing you of your options for recourse.
Q. If you disagree with Mantra’s refusal, can you request a review of this decision?
A. Yes. If Mantra refuses a request for access, portability, or correction, or if the request is not processed within the allotted timeframe, or only partially answered, you may file a request for a review of the disagreement with the Commission d’accès à l’information, which may issue orders and even impose penalties or award damages.
Security Measures
Q. What security measures does the law require for your Personal Information?
A. Mantra must implement security measures designed to protect your Personal Information. These measures must be reasonable, taking into account factors such as the sensitivity of the information, the purpose for which it is used, its volume, distribution, and format. Mantra takes reasonable steps to ensure that the Personal Information it collects, processes, and stores is complete, up to date, and used only for the purposes for which it was collected or for which authorization has been given.
Q. Where is your Personal Information stored at Mantra?
A. Mantra may store your Personal Information in its offices and IT systems located in Québec, elsewhere in Canada, or abroad. Mantra may also use service providers that store or process some of your Personal Information (for example, data storage and processing services, cloud services, application hosting services, or office services). In such cases, Mantra requires these providers to implement measures that ensure a level of protection comparable to that required by Mantra.
Q. What types of security measures has Mantra implemented?
A. Internally, Mantra implements physical, technical, and organizational security measures to protect your Personal Information.
Physical measures – for example, access control to offices (key fobs), server rooms, alarm systems, secure filing cabinets for paper documents containing Personal Information, closed offices, etc.
Technical measures – for example, confidentiality agreements signed by employees and affiliated companies, creation of strong passwords, encrypted communications, software updates, IT policies, effective, timely and random monitoring of equipment, web, and communication tool usage, document management systems, etc.
Organizational measures – limited access rights, templates including personal information protection clauses, governance policies and practices, an action plan in case of a privacy incident, employee training and awareness, etc.
Privacy Incident
Q. What is a privacy incident?
A. A “privacy incident” is defined as the unauthorized access, use, or disclosure of one of your Personal Information under applicable laws, or the loss of such information by a Mantra employee, or any other breach of the protection of that Personal Information.
Q. What does Mantra do in the event of a privacy incident?
A. If Mantra has reason to believe that a privacy incident, as defined by law, involves any of your Personal Information, Mantra will take reasonable steps to prevent harm and to avoid the recurrence of similar incidents. We will inform you (as well as the relevant authorities), in a timely manner, if we determine that the incident presents a risk of serious harm.
Q. Does this mean that Mantra guarantees the protection of your Personal Information?
A. As you may know, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, Mantra cannot ensure or guarantee the security of your Personal Information. It is possible that your Personal Information could be accessed, disclosed, altered, or destroyed as a result of a breach of the protective measures put in place by Mantra.
Q. What should you do if you witness or suspect a non-compliant situation involving your Personal Information or our security measures?
A. If you have reason to believe that Personal Information has been compromised or that there has been a breach of our security measures, please contact Mantra’s Privacy Officer without delay.
Privacy Complaint
Q. Can you file a complaint if you are dissatisfied with a practice, action, or inaction by Mantra regarding the protection of your Personal Information?
A. Yes. Mantra has established a process for handling complaints related to privacy matters.
Q. How do you file a complaint?
A. You can submit a written complaint addressed to the person responsible for this Privacy Policy at Mantra. This person will review the complaint and determine the actions to take to address your concern if it involves an issue requiring such action. Only the information necessary to process the complaint will be shared with Mantra staff who need to be informed in the course of their duties.
Q. Can a complaint be informal?
A. No. An informal approach aimed at correcting a particular issue, as long as it is handled within Mantra’s regular activities, is not considered a complaint requiring the formal complaint process.
Q. Can you file an anonymous complaint?
A. Yes. A complaint may be submitted anonymously, and it is prohibited to retaliate or threaten retaliation against anyone for having filed a complaint in good faith or for refraining from filing one.
Data Transfer Outside Québec
Q. Does Mantra disclose some of your Personal Information outside Québec?
A. Yes, on occasion, Mantra may disclose some of your Personal Information outside Québec, for example, to a service provider.
Q. How does Mantra ensure the protection of your Personal Information in such cases?
A. Before any transfer outside Québec, Mantra governs the process with a secure contract to ensure your Personal Information is used fairly, appropriately, and securely. Mantra also ensures in advance that your Personal Information will not be used for unrelated purposes. When applicable, Mantra conducts a Privacy Impact Assessment that takes into account the legal framework in the country where the Personal Information will be disclosed.
Q. Can your Personal Information be subject to the laws of other jurisdictions?
A. Yes. If some of your Personal Information is used outside Canada, it may be subject to the laws of the country where it is stored and used. In such cases, it may be subject to various forms of disclosure to government authorities, courts, or law enforcement agencies in accordance with that country’s laws. It is possible that some of our service providers store or host your Personal Information outside Canada. Therefore, if a law or order in that country requires it, foreign authorities may have access to your Personal Information. For any questions on this subject, please feel free to consult the person responsible for this Privacy Policy at Mantra.
Pharmacovigilance - Medical Information Department
Q. Did you know that for any questions regarding Mantra’s products, including drug interactions, potential side effects, ingredients, allergens, or any pharmaceutical or scientific inquiries, it is recommended to contact Mantra’s Medical Information Department by phone, email, or through the contact form on Mantra’s website?
A. Please feel free to contact us.
Q. Can Mantra record your call when you contact this department?
A. Yes, it is possible that when you contact Mantra’s Medical Information Department by phone, we use call recording technology to collect relevant information and respond to your inquiry or follow-up request. If you do not consent to such recording, please let us know. These recordings are destroyed as soon as their purpose has been fulfilled.
Q. And if you communicate by email with Mantra’s Medical Information Department, what kind of communications are preferred?
A. Mantra ensures that all documents and information sent to you are delivered securely and confidentially.
Cookies (Connection Tokens)
Q. In what context might Mantra use cookies?
A. Mantra may use cookies to analyze user preferences, customer consumption interests, or to remember customer information in order to facilitate navigation, among other purposes. Please consult the Website Terms of Use for more details.
Q. If Mantra wishes to collect cookies, what must it do?
A. Mantra must first inform you:
- of the use of such technology; and
- of the options available to enable functions that identify, locate, or profile you.
Mantra Websites – About Its Products and Services
Q. Does this Privacy Policy apply when you visit Mantra’s websites about its specific products and service?
A. Yes. This Privacy Policy applies, with necessary adjustments, in addition to the Terms of Use, which are an integral part of this Privacy Policy.
Limitation of Liability
Notwithstanding the above, Mantra cannot guarantee that third parties will not attempt to breach the security measures in place or misuse your Personal Information. Mantra does not monitor websites to which it may provide links, including those of its partners and sponsors.
Therefore, Mantra’s Privacy Policy does not apply to third-party websites. By clicking on a third-party website link, that site will have its own policies regarding the protection of your Personal Information. Mantra cannot be held responsible for any damages resulting from third-party practices.
Updates and Modifications
Mantra makes reasonable efforts to keep this Privacy Policy up to date. However, privacy laws and their interpretations are subject to rapid change. We make every effort to revise our practices and policies accordingly. It is recommended to review the Privacy Policy regularly for the latest version.
In this context, Mantra may amend this Privacy Policy from time to time without prior notice. If you use a Mantra website after such changes have been made, you signify your acceptance of the modified terms. Thus, the collection, use, disclosure, retention, and destruction of your Personal Information are governed by the version of the Privacy Policy in effect at that time.
The website https://www.mantrapharma.ca/ is the exclusive property of Mantra and was designed to provide information about products and services offered by Mantra.