Privacy Statement
Details & Explanatory Notes

Contact Us

Our Privacy Statement refers in various places to you contacting us in order to:

1. receive information;



2. receive a copy of the most current version of our Privacy Statement;



3. withdraw your consent to our retention, use or disclosure of your personal information;



4. access or correct your personal information; and,



5. communicate any questions, comments, or concerns about our Privacy Statement or practices.

Requests regarding items 3 - 5 above must be made in writing.

You may contact us by:

1. writing to us at the following address:
   
   Janssen-Ortho Inc.,
   Attention: Chief Privacy Officer,
   19 Green Belt Drive,
   Toronto, Ontario,
   M3C 1L9



2. calling us at 416-449-9444 and asking to speak to the Office or the Chief Privacy Officer;



3. faxing us at 416-449-2658, attention Chief Privacy Officer, Janssen-Ortho Inc.;



4. e-mailing us at chiefprivacyofficer@joica.jnj.com; or



5. going to our web site at: www.janssen-ortho.com.

NOTE: If you are a physician or other health care professional and have questions or comments regarding our products, please contact our Medical Information Group at 1-800-567-3331.

Purposes

We will collect and use personal information in order to:

1. reply to your requests, inquiries and comments;



2. provide our products and services and manage our business;



3. establish and maintain our relationship with health care professionals and administrators and other individuals with whom we have contact in the course of our business;



4. provide assistance and advice to health care professionals and institutions with respect to our products;



5. receive and assess product inquiries, reports of adverse events, and product complaints;



6. assist in or co-ordinate product recalls;



7. administer contests, promotions, surveys and web site chat rooms and bulletin boards;



8. develop and improve our products;



9. provide you with health and product-related medical information;



10. ensure the security and integrity of our web sites and operations;



11. provide remuneration to physicians who have participated in our advisory boards;



12. use feedback provided to us in the course of advisory board meetings to develop the strategic positioning of our products;



13. monitor compliance with informed consent requirements when patients participate in clinical trials, and verify that clinical data collected by Janssen-Ortho in the course of the clinical trial conforms to the source data available at the site of the clinical trial;



14. test and analyze our products for efficacy and safety;



15. meet legal, regulatory, ethical and processing requirements such as adverse event and clinical reporting to Health Canada and regulatory bodies;



16. enable us to act responsibly in the event of a health or other crisis or emergency and to enhance workplace security;



17. evaluate resumes or other personal information submitted to us in connection with employment possibilities, to assess whether to offer the employment candidate a position at Janssen-Ortho. For candidates who are not offered or do not accept a position, we may retain their information in the event that an appropriate position becomes available or that they re-apply to Janssen-Ortho.

We may also use your personal information for other purposes that are disclosed at the time of collection, or as otherwise permitted or required by law.

Consent

Consent to the collection, use and disclosure of your personal information may be given in various ways. Consent can be express (express consent may be oral, in writing or electronic), implied (such as when you provide your name and address in order for us to send you products or information you have requested) and may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with your personal information, we will assume that you consent to our collection, use and disclosure of such information as described in this Privacy Statement.

However, you may be asked to "opt in" or "opt out".

Opt In

In some cases you will, at the point of collection of the information, be given the option to "opt in" in order for you to provide your express consent to our collection, use and disclosure of such information by checking a box on a form, clicking on a specified icon on any of our web sites, or by doing some other specified action such as contacting us by telephone or by e-mail. Your personal information will in such case only be collected, used or disclosed for the purposes we describe at that time if you "opt in".

Opt Out

An "opt out" permits you to "opt out" of our collection, use and disclosure of your personal information by checking a box on a form, clicking on a specified icon on any of our web sites, or by doing some other specified action such as contacting us by telephone or by e-mail. Where this "opt out" option is available, your consent to our collection, use and disclosure of your personal information will be given unless you "opt out".

When you wish to participate in a promotion, contest or survey, you will not be required, as a condition of your participation, to provide more personal information than is necessary in order for us administer the promotion, contest or survey and to deliver any products you may be entitled to receive. However, you may be provided with the option of providing additional personal information. You may, for example, choose to provide additional personal information by completing a questionnaire on a contest ballot relating to your use of our products, in which case we may then use that information to assist us in developing, improving, and selling our products.

If you do not want your personal information collected by us, please 1) follow the procedures, where available, indicated at the point of collection to "opt out" so that your personal information is not collected, 2) if no "opt out" option is available, do not submit personal information to us, or 3) do not "opt in", where such option is available, so that your personal information is not collected.

If you have provided us with personal information and wish to withdraw your consent to its retention, use or disclosure, please contact us. You may withdraw your consent, subject to legal or contractual restrictions and reasonable notice.

Without Consent

There are instances where we may collect, use or disclose your personal information without your consent. Some examples for each type of exception are:

The "collection" circumstances include: The information is publicly available and is specified by regulations; the collection is clearly in the interests of the individual and consent cannot be obtained in a timely way; it is reasonable to expect that the collection with the knowledge or consent of the individual would compromise the availability or the accuracy of the information and the collection is reasonable for purposes to investigate a breach of an agreement or a contravention of the laws of Canada or a province.

The circumstances for use without knowledge or consent include: it is used for the purpose of acting in respect to an emergency that threatens the life, health or security of an individual.

The circumstances for "disclosure" without knowledge or consent include: to comply with a subpoena or warrant issued or an order made by a court.

Collection

Types Of Personal Information Collected

Janssen-Ortho and its agents and representatives may collect personal information such as:

1. personal and business contact information, such as name, title, address, telephone number and e-mail address;



2. information that our sales representatives may collect during their visits with physicians and other health care professionals with whom they deal, for instance title, qualifications, areas of practice or specialization, their questions or comments about our products, and related information relevant to maintaining and managing our relationship with health care providers and administrators;



3. names and other contact details of patients who use our products and their physicians and, in certain circumstances, sensitive health information, and patient medical history, which may be collected in circumstances where we have received a report of an adverse event, where we are providing patient-specific assistance with respect to the use of our products, or where we are assisting in or co-coordinating product recalls;



4. inquiries or comments about our products that are provided by individuals who contact our Medical Information representatives;



5. names and other contact details of physicians participating in advisory boards and the opinions or comments expressed by those physicians during advisory board meetings;



6. names and other contact details of physicians involved in running clinical trials, together with their professional information such as curriculum vitae and other information that is required to be reported to Health Canada and other regulatory bodies;



7. information such as name, age, and gender of patients participating in clinical trials together with the clinical data collected in the course of the clinical trials. Janssen-Ortho generally receives patients' clinical data that has been recorded using identifiers other than the patients' full name, such as the patients' initials. More comprehensive patient data, including full names, may be reviewed by our clinical site managers when they attend at the trial site for compliance monitoring;



8. information from individuals visiting our premises such as their name and the name of the organization for which they work or which they represent. We may also post video cameras in public-access areas on our premises.

Information (Personal Information and anonymous information) can be actively and passively collected by our web sites. See technology implications below for details.

How and When We Collect Personal Information

We collect your personal information where you provide it to us voluntarily, with your consent, or otherwise as permitted or required by law. We may collect your personal information when you:

1. request information;



2. inquire or provide comments about our products and services;



3. participate in advisory boards;



4. participate in clinical trials;



5. participate in contests or other promotions;



6. fill out questionnaires or surveys;



7. participate in chat rooms, or post information on bulletins or on our web sites;



8. submit your resume or other personal information in connection with employment possibilities with us; or



9. otherwise provide your personal information by telephone, mail, facsimile or through any of our web sites.

Technology Implications

Active Information Collection

Our web sites may actively collect information from its visitors both by asking you specific questions and by permitting you to communicate directly with us via e-mail and/or feedback forms. Some of the information that you submit on our web sites may be personal information.

Passive Information Collection

As you navigate through our web sites, certain anonymous information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the web site some of this anonymous information, such as the URL of the web site you just came from and the Internet Protocol (IP) address and the browser version your computer is currently using. Our web sites may also collect anonymous information from your computer through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of our web sites might not work without cookies.

Our web sites may use and combine such passively collected anonymous information to provide better service to site visitors, customize the sites based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the sites for your use. Such information is not combined with personal information collected elsewhere on our web sites unless you have consented.

Cookies

The following is a description of cookies and other passive tracking methods.

A "cookie" is a bit of information that a web site sends to your web browser that helps the site remember information about you and your preferences.

"Session" cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate and collect aggregate statistical information on the site. They are erased once you exit your web browser or otherwise turn off your computer.

"Persistent" cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the web site visitors find most valuable, and customizing the web site based on your preferences on an ongoing basis.

You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. To learn more about cookies and how to specify your preferences, please search for "cookie" in the "Help" portion of your browser.

IP Addresses and Tags

A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered not to be personal information because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.

"Internet tags" (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the web site server information such as the IP address and browser type related to the visitor's computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted.

"Navigational data" (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors.

Disclose

JANSSEN-ORTHO will not disclose your personal information to any person except in the following circumstances, and then only that information which is deemed necessary:

We may disclose personal information when required in order to meet legal or ethical requirements, including obligations to health and drug regulatory and self-regulatory bodies, physicians, hospitals, or other health care facilities. In most cases involving personal health information, we will obtain more detailed consent from all patients involved.

Your personal information may be used by Janssen-Ortho and disclosed to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of Janssen-Ortho's business or assets, including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction or business relationship, to fulfil reporting or audit requirements or the use and disclosure by those parties for substantially the same purposes as described in this policy.

We also may disclose your personal information to third parties, located in Canada and/or any other country where required or permitted by applicable laws, court orders, or government regulations.

Security

Although we have enacted security measures, we cannot guarantee the security of any information that you submit via e-mail or over the Internet. Submission of personal information using such networks is done at your own risk, since no Internet transmission is ever 100% secure or error-free (in particular, e-mails sent to or from our web sites may not be secure). You should take special care in deciding what information you send to us via e-mail or posting on our web sites. Moreover, where you use passwords, ID numbers or other special access features on our web sites, it is your responsibility to safeguard them. Our web sites may contain links or references to other web sites to which this Privacy Statement does not apply. Janssen-Ortho is not responsible for the data collection and use practices of companies or organizations to which the Janssen-Ortho web sites may provide links. We encourage you to read the privacy statement/policy of every web site you visit.

Access Exceptions

Some information may not be accessed in certain limited circumstances. Some examples include:

• information that contains references to other individuals,
• information that cannot be disclosed for legal, security, or commercial proprietary reasons,
• information that is subject to solicitor-client or litigation privilege, and
• information that is prohibitively costly to provide,

The Chief Privacy Officer must approve all exceptions to access. The reasons for denying access shall be provided by JANSSEN-ORTHO upon request.

Definitions