Please read this Privacy Notice (“Notice”) carefully to understand Our policies and practices regarding your Personal Data and how We will treat it. This Notice applies to individuals who interact with Galderma services as set out below, including patients, consumers, and healthcare professionals (“you”). This Notice explains how your Personal Data is collected, used, and disclosed by Galderma Canada Inc. and its affiliated entities (“Galderma”, “We”, “Us”, “Our”). It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data is used.
In this Notice, “Personal Data” means any information that identifies you or can be used to identify you (such as your name, contact information, and health information). It does not apply to business contact information (such as your business email address or business phone number) if you provide it to Us for business purposes.
This Notice covers both Our online and offline data collection activities, including Personal Data that We collect through Our various channels such as Our websites, third party social networks and through Our vigilance activities.
By using or accessing the Sites or otherwise interacting with Us, you agree to the collection, use, and disclosure of your Personal Data as described in this Privacy Notice. If you do not wish to provide Personal Data to Us, in some cases, We may not be able to provide you with Our goods and/or services.
We comply with applicable Canadian privacy laws, which may include additional rights or requirements depending on your province of residence.
This Notice provides important information in the following areas:
1. SOURCES OF PERSONAL DATA
2. PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
3. PERSONAL DATA OF CHILDREN
4. COOKIES/SIMILAR TECHNOLOGIES
5. USES MADE OF YOUR PERSONAL DATA
6. DISCLOSURE OF YOUR PERSONAL DATA
7. RETENTION OF YOUR PERSONAL DATA
8. PROTECTION OF YOUR PERSONAL DATA AND CROSS-BORDER TRANSFERS
9. YOUR RIGHTS
10. CHANGES TO THIS NOTICE
11. CONTACT US
We may collect Personal Data from or about you from the following sources:
Galderma websites, meaning Websites operated by or for Galderma, including sites that We operate under Our own domains/URLs and mini-sites that We run on third party social networks such as Facebook (“Websites”). Please see “COOKIES/SIMILAR TECHNOLOGIES” below for more information on what data We may collect through the Websites.
E-mail, text and other communications, meaning Interactions between you and Galderma. This includes any personal health information you may share with Us when reporting an adverse event or defect with a product or service. In the course of Our interactions with you, We may create Personal Data about you (e.g. records of your interactions with Our Websites).
Healthcare providers and program administrators. With your consent, We may collect Personal Data when you enroll or participate in clinical trials, patient support programs, research programs, or receive other services. This may be collected from you, your healthcare provider, and third-party service providers associated with any such program or trial.
We may also obtain Personal Data about you from your healthcare provider to report an adverse experience in relation to one of Our products, only if you have provided your consent. Your healthcare provider is responsible for obtaining this consent before sharing any information with Us.
Data from other sources. We may obtain Personal Data about you from Our third-party social media and marketing partners (such as Meta and Google), market research (if feedback is not provided on an anonymous basis), events, public sources, and data received when We acquire other companies.
2. PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Depending on how you interact with Galderma (online, offline, over the phone, etc.), We collect various types of information from you, as described below.
Personal contact information. This includes any information you provide to Us that would allow Us to contact you, such as your name, postal address, e-mail address, phone number or fax number.
Professional information (healthcare professionals). This includes any information you provide to Us relating to your profession and qualifications, but also information found in your curriculum vitae; information about your current and past interactions with Galderma, information relating to your prescription activity that may be used for market analysis, compliance with regulatory obligations, or informing Our interactions with healthcare professionals, and about your participation in events, conferences and scientific studies; and other personal information that you may provide about yourself and your professional activities.
Information from computer/mobile device. This includes any information about the computer system or other technological device that you use to access one of Our Websites, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a Galderma Website via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location, and other similar mobile device data.
Websites/communication usage information. As you navigate through and interact with Our Websites or newsletters, We use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected through the use of third-party tracking for analytics and advertising purposes. You have the right to object to the use of such technologies. For further information, please see “COOKIES/SIMILAR TECHNOLOGIES” below.
Consumer-generated content. This includes any content that you create and then share with Us on third party social networks or by uploading it to one of Our Websites, including the use of third-party social network apps such as X/Twitter. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, We collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third-party social networking.
Third party social network information. This includes any information that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as X/Twitter) and that you allow the third-party social network to share with Us. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third-party social network to share. We receive your third-party social network profile information (or parts of it) every time you download or interact with a Galderma web application on a third-party social network such as X/Twitter, every time you use a social networking feature that is integrated within a Galderma site (such as Facebook Connect), and every time you otherwise interact with Us through a third-party social network.
Please note, however, that this Privacy Notice does not apply to the third-party social networks. To learn more about how your information from a third-party social network is obtained by Galderma, or to opt-out of sharing such social network information, please visit the website of the relevant third-party social network.
Information obtained through clinical trials and patient support programs. When you enroll in a patient support program, clinical trial, or other similar program, We provide you with details about what specific Personal Data We may collect about you and provide you with an opportunity to consent to such collection at that time. Though the specific information obtained will depend on the program, if you provide your consent, Personal Data collected through these programs may include your contact information, personal details like gender and date of birth, and personal health information (such as medical history, medical condition(s), information relating to your treatment and prescription(s), and information relating to your health insurance coverage). We may also collect such information to meet Our legal and regulatory obligations, including adverse event reporting.
We do not knowingly solicit or collect Personal Data from children below the age of 13. If We discover that We have unintentionally collected Personal Data from a child below 13, We will remove that child’s Personal Data from Our records promptly. However, Galderma may collect Personal Data about children below the age of 13 years of age from the parent or guardian directly, and with that person’s explicit consent as required by law.
4. COOKIES/SIMILAR TECHNOLOGIES
Cookies/Similar Technologies. Please see Our Cookie Policy to learn how you can manage your cookie settings and for detailed information on the cookies We use and the purposes for which We use them.
We also use Google Fonts, which is a web font service provided by Google that enables the optimization of Our Websites providing the correct fonts. We host Google Fonts locally without ever having to connect to a Google Server and thus collect IP addresses.
5. USES MADE OF YOUR PERSONAL DATA
The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.
What We use your Personal Data for | Why We use it |
Patient/Consumer service. We use the Personal Data of patients and customers for consumer service purposes, including responding to your inquiries. We collect information about how Our Websites are used to be able to provide you with certain content and improve it based on the feedback We receive. Responding to your inquiries typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. responding to any questions or concerns you may have concerning your use of Our products, order status, technical issue, product question/complaint, general question, etc.). |
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Establishing and maintaining Our relationship with healthcare professionals. We use the Personal Data of healthcare professionals to verify whether there is a potential business opportunity, reach out to you and inform you about Our products and services, invite you to events and maintain a relationship with you. |
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Contacting you and conducting advertising on third party social networks. We use your Personal Data when you interact with third-party social networking features, such as “Like” functions, to serve you with advertisements and engage with you on third-party social networks. You can learn more about how these features work, the profile data that We obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third-party social networks. |
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Legal reasons or merger/acquisition. In the event that Galderma or its assets are acquired by, or merged with, another company including through bankruptcy, We will share your Personal Data with any of Our legal successors. We will also collect and use your Personal Data to comply with Our legal obligations (e.g., tax law, adverse event reporting, and product safety obligations). |
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For Website usage analytics. We may also collect and process information about your visit to Our Website, such as the pages you visit, the website you came from and the searches you perform. We may use such information to help improve the contents of the Website and to compile aggregate statistics about people using Our site for Our internal usage statistics and market research purposes. In doing this, We may install “cookies” that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. |
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For patient support programs and clinical research. We may collect and use personal health information about you (such as medical history, medical condition(s), information relating to your treatment and prescription(s), or information relating to your health insurance coverage) for the purposes of administering patient support programs or clinical trials. If you enroll in any such program or clinical trial, We will provide you with more details about how your information will be handled at the time of enrollment. We only collect and use this information if you choose to enroll in such programs or trials and have provided your separate consent. |
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In case We want to use your Personal Data for purposes unrelated to those described in this Notice, We will first notify you and, where required, offer you a choice as to whether or not We may use your Personal Data in this manner.
6. DISCLOSURE OF YOUR PERSONAL DATA
We share your Personal Data with third parties in order to provide Our services, for the purposes described in this Privacy Notice, or for purposes that are separately communicated to you by Galderma. We may share information with the following types of organisations:
Other Galderma subsidiaries and affiliates worldwide. Galderma SA (the parent company of Galderma Canada Inc.) and its subsidiary companies may share your Personal Data amongst and between each other for the purposes set forth in this Privacy Notice.
Service providers. These are external companies that We use to help Us run Our business. We use service providers to perform various services on Our behalf, including:
Website operation and development
Technology support services
Third-party administration of patient support programs
Data analytics
Clinical research and reporting
Service providers, and their selected staff, are only allowed to access and use your Personal Data on Our behalf for the specific tasks that they have been requested to carry out, based on Our instructions, and are required to keep your Personal Data confidential and secure.
Digital marketing partners. We may exchange information with trusted third-party partners that provide Us with advertising and digital marketing services, such as the social networks referenced above through which We serve targeted advertisements to you.
Third party recipients using Personal Data for legal reasons or due to merger/acquisition. We will disclose your Personal Data to other third parties for the following purposes:
To governmental and regulatory bodies worldwide including in connection with monitoring products and services, adverse event reporting, and as otherwise required to comply with legal and regulatory requirements.
In the context of a corporate business transaction (such as an acquisition or a merger), in which case We will require such third parties to use and protect your Personal Data consistent with this Privacy Notice. We may also share your Personal Data with third parties that were formerly wholly or partly included in the Galderma family of companies to whom We provide services during a transition period following separation. (see Section 5 for details).
To otherwise protect Our rights, interests, personnel, or property including to establish or respond to legal proceedings, investigate potential wrongdoing, respond to a legitimate request from a law enforcement agency, protect you and Us against fraud and other illegal activity, and to enforce the terms of any agreement or the terms of Our Website.
Healthcare providers and insurance providers. If you enroll in a patient support program, your Personal Data (including personal health information) may be exchanged between Galderma, your healthcare provider(s), the third-party administrator of the program, and your health insurance provider(s). We require that all parties involved in such programs protect your Personal Data consistent with this Privacy Notice, and We will obtain your separate consent for the use and disclosure of your health information at the time of enrollment.
We require all service providers, whether located in Canada or outside Canada (including outside Québec), to provide a level of protection for Personal Data that is comparable to the protections required under Canadian law. Written contracts are in place with service providers to ensure your Personal Data is only used for authorized purposes and is kept secure and confidential.
7. RETENTION OF YOUR PERSONAL DATA
Galderma takes every reasonable step to ensure that your Personal Data is only retained for as long as necessary to fulfill the purposes for which We collected it.
We will typically only retain your Personal Data for as long as: (i) We maintain an ongoing relationship with you, (ii) retaining the information is otherwise necessary in connection with any of the purposes set out in this Notice, or (iii) may be required or permitted by applicable laws and regulations.
Once these periods have concluded, We will either (i) permanently delete or destroy the relevant Personal Data or (ii) anonymise the relevant Personal Data. For certain categories of information, such as clinical trial or patient support program data, We apply specific retention schedules as required by law or regulation.
8. PROTECTION OF YOUR PERSONAL DATA AND CROSS-BORDER TRANSFERS
We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.
People who can access your Personal Data. Your Personal Data will be processed by Our authorised staff or agents, on a need-to-know basis, depending on the specific purposes for which your Personal Data have been collected.
Measures taken in operating environments. We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although We will do Our best to protect your Personal Data, We cannot guarantee the security of the data during transmission through Our Websites.
Transfer of your Personal Data. We may transfer your Personal Data to Our affiliates, partners, service providers, or other trusted third parties that may be located outside of Canada or your province of residence, including Switzerland, UK and the USA, where it may accessed, stored, or otherwise processed. When We share your Personal Data with an entity located outside of Canada or your province, We put in place appropriate safeguards to help ensure that your Personal Data is adequately protected. In Québec, before transferring Personal Data outside the province, Galderma conducts a privacy impact assessment as required by law. When your Personal Data is transferred to a jurisdiction outside of your province or Canada, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts, and law enforcement in that jurisdiction.
When your Personal Data is transferred to a jurisdiction outside of your province or Canada, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts, and law enforcement in that jurisdiction.
Accessing and correcting your Personal Data
If you believe that the Personal Data We maintain about you is not correct, you can make a request to correct it by writing to the Privacy Officer using the contact information set out below. You may also request access to the Personal Data that We maintain about you by writing to the Privacy Officer.
To process such a request, We will require appropriate evidence of your identity. In addition, in some circumstances, the Personal Data We have in our systems will be in insufficient detail to identify you and We may need to ask you to provide additional relevant personal information before We can process your request.
If you are submitting a request on behalf of someone else, it may be necessary that We verify your authority to submit such a request. You may therefore be asked to provide signed confirmation that you are permitted by the data subject or by law to submit such request.
In some cases, Our legal obligations will prevent Us from granting a request for access to or correction of Personal Data. We will inform you in writing of the reasons for any such decision.
Withdrawing your consent
You may have the right to withdraw the consent you have previously provided to process your Personal Data under certain circumstances. However, in some cases this may mean that We can no longer provide you with certain information, products, or services. Please contact the Privacy Officer using the contact information set out below for more information.
If you have signed up to receive marketing or promotional messages from Us via email or text message, you always have the option to unsubscribe. You can do so by contacting Us or using the unsubscribe mechanism contained in the message.
Automated decisions
We generally seek to inform you when or before We make an automated decision about you. If you have any questions or concerns about an automated decision involving your information, you can contact the Privacy Officer using the contact information set out below.
Additional rights
Depending on where you live, you may have the option to exercise additional privacy rights, in accordance with applicable provincial or territorial laws. Please contact the Privacy Officer using the contact information set out below for more information on your privacy rights.
If you are a resident of Québec, these rights include the right to data portability and the right to request cessation of dissemination or de-indexing of your Personal Data, subject to legal limits.
If you are based in the US, please visit Our US Privacy Notice to learn how to exercise your privacy rights. If you are based in the EEA or any other country, please visit Our Global Privacy Notice for more information.
If We change the way We handle your Personal Data, We will update this Notice. We reserve the right to make changes to Our practices and this Notice at any time. Please check back frequently to see any updates or changes to this Notice.
11. CONTACT US
You may contact Us with questions, comments, or complaints about this Privacy Notice or Our privacy practices. When raising a question, comment, or complaint, please provide sufficient details (including your relationship with Us) and any relevant documentation.
The contact information for Our Privacy Officer is:
Galderma Canada Privacy Officer
Galderma Canada Inc.
161 Bay Street
Suite 3900
Toronto, ON M5J 2S1
Privacy.Officer.Canada@galderma.com
Last updated: October, 2025