01About this policy
TLC Pharmaceutical Standards Ltd. ("TLC", "we", "us" or "our") respects your privacy. This policy explains how we collect, use, disclose, retain and protect personal information when you visit www.tlcstandards.com and any related TLC-operated websites or online services (collectively, the "Website"), request a quotation or product document, place or administer an Order, receive Products or Services, or otherwise communicate or do business with us. It also explains your privacy choices and how to contact us about your information.
Personal information means information about an identifiable individual. "Order", "Products", "Services" and "Customer Materials" have the meanings used in TLC's Website and Sales Terms and Conditions (the "Terms"). This policy applies to Website visitors and to individuals who interact with us on behalf of a customer, prospective customer, supplier, distributor, service provider or other business organization. It does not describe our handling of employment applications or employee records. Because TLC primarily deals with organizations, some business information may not be personal information under applicable law; this policy applies to it only to the extent it is personal information. The Terms govern Website use and transactions with TLC, while this policy describes TLC's handling of personal information. Nothing in this policy limits rights or obligations that cannot lawfully be limited.
TLC's Privacy Officer is responsible for overseeing our compliance with this policy and applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable Canadian or Ontario laws. The law that applies may depend on the nature of the activity, the information and the individuals involved. Questions or concerns may be directed to the Privacy Officer using the contact information in section 12. For the processing described in this policy, TLC generally determines the purposes and means of processing.
02Information we collect
Information you provide. We collect contact and business information you provide when requesting a quotation, product documentation or assistance, placing or administering an Order, arranging delivery, submitting Customer Materials, or otherwise dealing with us. Depending on the interaction, this may include your name, contact details, title or role, organization and country, account, quotation, Order, invoice, shipping and transaction details, product, lot, claim or support details, and correspondence, attachments or other information you choose to submit.
Please provide only information relevant to your interaction with TLC. Do not include patient information, medical records, payment-card details or other sensitive personal information in Website forms, ordinary email or attachments. Our Products and Services are for professional, laboratory and business purposes and we do not request patient or clinical information through the Website. Website forms and ordinary email are not a substitute for an agreed secure transfer method or a confidentiality agreement where one is needed. If you provide another person’s information, you must be authorized to do so and, where required, have given that person appropriate notice or obtained consent.
Information collected automatically. When you use the Website, our systems may record an IP address, browser or device information, request and response details, dates and times, referring pages, pages or files requested, and error, performance or security information in operational logs. These logs are retained for a limited period appropriate to their operational, diagnostic and security purposes. We also use a cookie and temporary records associated with a session identifier to maintain your quotation list as you move between pages. These temporary quotation-list records do not contain your name or email address.
We keep anonymous aggregate counts of product-certificate views, without attaching visitor identities to those counts. These counts are separate from server logs, which may contain information that can identify a visitor.
Information from other sources. We may receive business contact or transaction information (which may include your personal information) from your organization or its representatives and, where relevant to an interaction, from carriers, service providers, public records or authorities. We use such information only for the purposes described in this policy and as permitted by applicable law.
04Cookies and tracking
The Website uses an essential functional cookie to remember your in-progress quotation list between pages. A cookie is a small file stored by your browser. This cookie supports a feature you request rather than advertising. You can block or delete cookies through your browser settings, although doing so may prevent the quotation-list feature from working properly.
As of the Effective Date, TLC does not use analytics or advertising cookies, tracking pixels, or scripts that track visitors for advertising or across websites. This does not prevent the routine server logging and anonymous document-view counting described above.
05Who may receive information
Within TLC. Website enquiries are delivered to TLC mailboxes and information may be routed to the team responsible for your country, request, Order, delivery, Services or customer relationship. Access is limited to personnel who need the information for their work.
Service providers and transaction participants. We may disclose information as reasonably necessary to providers that support email, hosting or other technology; quotation, Order and customer administration; payment, credit, fraud prevention, debt collection, shipping, customs or delivery; professional advice, insurance or claims; security; records management; or Products and Services, including qualified subcontractors. We require providers processing personal information on our behalf to use it only for authorized services, protect it through appropriate contractual or other measures and comply with applicable law. Carriers, customs intermediaries, financial institutions or other independent participants may handle information under their own legal obligations and privacy notices.
Legal requirements. We may preserve, use or disclose information where required or permitted by applicable law, including to courts, law enforcement, regulators, customs or other authorities; to respond to valid legal process, audits, inspections or investigations; to meet product, trade, tax, recordkeeping or reporting obligations; to establish, exercise or defend legal claims; or to protect rights, safety, property and systems against fraud, unlawful activity or security threats. Any such action is limited to what is appropriate in the circumstances. Where lawful and practical, TLC may notify an affected organization or individual before making a compelled disclosure.
Business transactions. We may disclose personal information to a prospective or actual purchaser or transaction partner where reasonably necessary to evaluate or complete a merger, acquisition, financing, reorganization, sale of assets or similar business transaction. Any such disclosure will be subject to appropriate confidentiality, use and security restrictions and applicable law. Where required, we will notify affected individuals if the transaction is completed and their personal information is transferred, and we will use reasonable efforts to require the receiving party to handle the information in a manner substantially consistent with this policy or to provide notice of any material changes.
We do not sell or rent personal information, or disclose it to third parties for their own advertising purposes.
06Processing outside Canada
Depending on the TLC team handling your request and the service providers involved, personal information may be accessed, processed or stored outside your province, territory or country, including outside Canada. Privacy laws in those locations may differ from those where you are located, and information may be accessible to courts, law enforcement, regulators or other authorities under local law.
TLC remains accountable for personal information under its control and uses contractual or other appropriate measures intended to provide a comparable level of protection when a provider processes that information on our behalf. Where another applicable law restricts international transfers, we use a recognized transfer mechanism, contractual safeguards or an available legal exception, as appropriate. Information transferred internationally remains subject to the legal requirements of the recipient jurisdiction. Contact us using the details below if you would like more information about our service providers, the countries in which information may be processed or the measures used for international processing.
07Retention, accuracy, and security
We retain personal information only as long as reasonably necessary for the purposes described in this policy, including to administer enquiries, Orders, Products, Services and customer relationships; maintain business, quality, tax, trade and regulatory records; resolve disputes; enforce agreements; and meet legal requirements. The period depends on the information’s nature and sensitivity, the relevant business relationship, legal or contractual requirements, limitation periods and whether a record is needed for an actual or anticipated dispute. Temporary quotation-list records are kept for a limited period to support that feature. When personal information is no longer needed, we delete it, make it anonymous or otherwise dispose of it using measures appropriate to its sensitivity, subject to applicable retention and legal-hold requirements. Residual copies may remain temporarily in backups or disaster-recovery systems until overwritten or deleted in the ordinary course and remain subject to safeguards while retained. We may retain information that has been irreversibly de-identified where permitted by law.
We take reasonable steps to keep personal information as accurate, complete and up to date as necessary for the purposes for which it is used. Please contact us if you believe that information we hold about you is inaccurate or incomplete.
We use reasonable administrative, technical and physical safeguards appropriate to the sensitivity of the information. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. In the event of a breach of security safeguards involving your personal information that creates a real risk of significant harm, we will notify you as soon as feasible and to the extent we are reasonably able to do so, and report to the appropriate authorities as required by applicable law. If we become aware of a privacy or security incident, we will take reasonable steps to contain it, investigate its scope and cause, reduce potential harm and prevent recurrence.
We will keep required records and notify affected individuals and report to regulators or other organizations where required by applicable law.
08Your choices and privacy rights
You may choose whether to provide information through the Website. If you do not provide information needed to respond, we may be unable to complete your quotation, documentation or support request. We seek consent where required by applicable law; simply visiting the Website does not constitute consent to unrelated uses of your information.
You may contact us to ask whether and how we handle your personal information, request access to or correction of it, or raise a concern about how it has been handled. We will respond to such requests within 30 days or as otherwise required by applicable law, and may extend this period where applicable law permits, with written notice to you of the reason and expected response date. Where applicable law outside Canada specifically provides these rights, you may also request deletion or restriction of processing, object to processing, or request a portable copy of your personal information. You may withdraw consent to future processing based on consent. These rights are subject to applicable legal limits, including requirements to retain certain records. Withdrawing consent may affect our ability to continue assisting you.
Access, correction, deletion and other rights may be limited where required or permitted by law, including where responding would reveal another person's information, disclose information protected by legal privilege or confidential commercial information, interfere with an investigation, be manifestly unfounded, excessive or repetitive, or conflict with a legal retention obligation. Where reasonable and legally required, we may provide access after severing protected information. If we cannot fulfill all or part of a request, we will explain the reason and any available recourse, subject to legal restrictions.
We may need to verify your identity and authority before responding and will request only information reasonably needed for that purpose. You may use an authorized representative where applicable law permits, but we may require proof of that authority. We do not ordinarily charge for a request; if applicable law permits a fee, we will give advance notice.
If you have a privacy concern or complaint, please contact our Privacy Officer first so that we can investigate and try to resolve it. We may ask for details and will communicate the outcome subject to applicable law. You may also contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or 1-800-282-1376, an applicable provincial privacy regulator, or another privacy or data-protection authority with jurisdiction over your concern.
Jurisdiction-specific rights. Depending on where you are located or where our processing occurs, local law may provide additional rights or impose additional requirements. For example, individuals in the European Economic Area or United Kingdom may have rights relating to objection, restriction, portability and complaints to a local supervisory authority where the relevant law applies. We will apply those requirements to the extent they govern our activities. Contact the Privacy Officer for information about rights applicable to your circumstances.
09Links to other websites
The Website may link to websites or services operated by other organizations. TLC does not control their privacy practices, and this policy does not apply to them. Their handling of personal information is governed by their own notices and practices. A link does not by itself mean that TLC endorses the organization’s privacy practices. Review the applicable privacy notice before providing information.
10Children
The Website, Products and Services are intended for business, institutional and professional users and are not directed to children under the age of 16 or minors. We do not knowingly collect personal information from children through the Website. If you believe a child has submitted personal information to us without appropriate authorization, please contact us so we can review the matter and delete or otherwise address the information as required by applicable law.
11Changes to this policy
We may update this policy as our practices, services or legal obligations change. The current version will be posted on the Website with its Effective Date and will apply from that date unless stated otherwise. We encourage you to review this policy periodically. For a material change to how we collect, use or disclose personal information, we will provide additional notice, which may include a prominent notice on the Website, and obtain consent where required by applicable law. A new purpose will not apply retroactively to previously collected personal information where notice or consent is legally required.