As of November 2021
Psygen Industries Ltd. (“Psygen” or “we”) undertakes work related to manufacturing of active pharmaceutical ingredients and research chemicals for use in clinical trials or other research (the “Services”). Psygen receives, retains, and safeguards information in the course of developing the Products or providing the Services to any individual who is a user of the Psygen website or who interacts with Psygen in the context of receiving the Services (collectively or individually, a “User”). Some of the information Psygen receives is Personal Information relating to Users as defined below.
Purpose and Definitions
This privacy policy describes Psygen’s Personal Information management practices including in relation to providing the Services, browsing the Psygen website (the “Site”) and subscribing to the Psygen newsletter. More specifically, this privacy policy describes the purposes for which Psygen collects, uses and discloses personal information, including personal health information, of a User, or other visitors to the Site.
In this privacy policy, “Personal Information” means information about an identifiable individual, such as a User, including in some cases information relating to the individual’s physical health, mental health, health history, health care providers or health care services.
Amendments to Privacy Policy
Psygen reserves the right to amend this privacy policy in response to changes in the Services, changes in Applicable Law as defined below, changes in policies applicable to the Services or in response to other motivations. The date on which this privacy policy was last amended is shown at the top of this privacy policy. You are responsible for verifying whether amendments have been made to this privacy policy. As in the Psygen Website Terms and Conditions, located at [NTD: insert link to Psygen Website Terms and Conditions], your access to the Site or use of the Services after amendment of this privacy policy will be understood to be your agreement to Psygen Website Terms and Conditions and the collection, use and disclosure of your Personal Information in accordance with the amended privacy policy.
Psygen’s Legal Obligations
Psygen has obligations as a provider of the Services. Psygen’s obligations are based on applicable federal, provincial or local law as may be appropriate in the context, including privacy legislation, the Controlled Drugs and Substances Act (Canada), the Food and Drugs Act (Canada), the Food and Drug Regulations (Canada), the Criminal Code (Canada), the Civil Code (Québec), other statutory law and regulations, common law (collectively or in any combination, “Applicable Law”). These obligations include limits on the collection and disclosure of certain Personal Information. No agreement between you and Psygen can override a legislative requirement to collect, use or disclose your Personal Information and to retain your Personal Information for a specified period of time.
In addition to the Personal Information that Psygen is required to collect, you may voluntarily provide us with additional Personal Information. With your express consent, we will use such Personal Information provided by you for medical or market research, education, improving the Services and other offerings, or otherwise improving the experience of our Users.
Collection, Use, and Storage of Personal Information
Psygen collects and uses Personal Information in the course of providing the Services. Once Psygen receives Personal Information, the Personal Information is stored digitally or in hard copy. All hard copies and digital records of Personal Information are stored on encrypted servers.
Disclosure of Personal Information
Psygen may also disclose your Personal Information for the purposes of a court, administrative, or other proceeding to which it is a party, as permitted by Applicable Law.
If Psygen is required to disclose Personal Information pursuant to a court order, subpoena, warrant or other legal requirement, or discloses your Personal Information for the purposes of a court, administrative, or other proceeding to which it is a party, Psygen will not disclose any more Personal Information than required for the purpose and will, to the extent permitted by Applicable Law, provide you with notice of the disclosure. There are circumstances, for example where a criminal investigation is in progress, where Psygen may be prohibited from notifying you of a disclosure obligation.
Personal Information of Visitors to the Psygen Website
When you visit the Site, we may collect technical information, which may include the address of the Site that you visited before visiting the Psygen Site, the pages of the Site that you visit, the browser you used to view the Site, the search terms you entered on the Site, and other such technical data (“Technical Information”). The Technical Information may not in itself constitute Personal Information.
We aggregate the Technical Information we collect from visitors to the Site and use the aggregate Technical Information to measure and improve the effectiveness of the Site and improve its content and responsiveness to visitor interests. We will not combine the Technical Information with any Personal Information. For clarity, the aggregate Technical Information we produce in relation to use of the Site does not identify individual Users.
We may disclose the aggregate Technical Information about the use of the Site to our service providers, regulatory bodies, and others.
We may also use services such as Google™ Analytics and other forms of cookies on our website that collect information about users of our website to tailor marketing information to them. We will not collect Personal Information about you in this way or for this purpose without your consent.
Subscribing to the Psygen Newsletter and Other Communications
Psygen publishes a newsletter and provides other mass communications about scientific research, regulatory progress and developments, and legal considerations relevant to psychedelics, offers and opportunities, or other messages related to Psygen, the Services, psychedelics, pharmaceuticals more generally, or other topics. The Psygen newsletter and other mass communications are available to the public generally and there is no requirement to access the Services to receive the Psygen newsletter and other communications. If you are accessing the Services, the Psygen newsletter and other mass communications do not identify you as such in being addressed to you. Please note that separate from the Psygen newsletter and any mass communications, persons accessing the Services may also receive specific communications relating to the Services, provision of the Services and special offers.
You may subscribe to the Psygen newsletter or consent to receive other mass communications through the Site. Subscribers may terminate their subscription at any time. The materials and notices we send by email include simple instructions and a link for you to unsubscribe. If you have any trouble unsubscribing, please contact our Privacy Officer as set out below.
Access and Correction of Personal Information, and Other Inquiries
You may request access to and the correction of your Personal Information in our records. You may request confirmation of the location of your Personal Information. Except in circumstances established by Applicable Law, you have a right to access any of your Personal Information in Psygen’s records. If on review of your Personal Information from our records, you believe that there are inaccuracies, please communicate details to us in writing about the inaccuracies. To the extent that Psygen is satisfied that your Personal Information in our records is inaccurate, we will correct our records.
If you want clarification of this privacy policy, additional information about our Personal Information management practices or our management of your Personal Information, or if you want us to investigate any concerns you have about our use or disclosure of your Personal Information, please contact our Privacy Officer as set out below.
Please note that email is not a secure means of communication. You assume all risk in relation to your decision to transmit Personal Information or confidential information to us by email, or to receive communications from Psygen by email.
Contact for Psygen Privacy Officer:
Email: privacy@psygen.ca
Attention: Privacy Officer
For inquiries unrelated to privacy, please contact info@psygen.ca.
