At Eupraxia Pharmaceuticals (“Eupraxia”) we are committed to providing our prospective patients (“Patients”) and our healthcare professionals, research partners and investors (collectively, “Partners”) with exceptional service. As providing this service involves the collection, use and disclosure of some Personal Information about our Patients and Partners protecting their Personal Information is one of our highest priorities.

This privacy policy (the “Privacy Policy”), in compliance with British Columbia’s Personal Information Protection Act (“PIPA”), sets forth the privacy principles, procedures and technical security measures that we use to protect Personal Information of our Patients and Partners.

We will inform our Patients and Partners of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their Personal Information in a manner that a reasonable person would consider appropriate in the circumstances. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our Patients’ and Partners’ Personal Information and allowing our Patients and Partners to request access to, and correction of, their Personal Information.

Scope of this Policy

This Privacy Policy applies to Eupraxia, its subsidiaries: Eupraxia Pharma, Inc., Eupraxia Holdings, Inc. and Eupraxia Pharmaceuticals USA, LLC, and its website, eupraxiapharma.com (the “Site”). This Privacy Policy also applies to any service providers collecting, using or disclosing Personal Information on behalf of Eupraxia.

This Privacy Policy does not cover personal information collected in the course of conducting clinical trials. Clinical trials are subject to their own privacy policies.

The Privacy Notice for our European Trial study EP104 can be found here.

Definitions

Personal Information – means information about an identifiable individual, including name, e-mail address, home address and telephone number. Personal Information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this Privacy Policy or PIPA.
Privacy Officer – means the individual designated responsible for ensuring that Eupraxia complies with this Privacy Policy and PIPA.

Collecting Personal Information

Unless the purposes for collecting Personal Information are obvious and the Patient or Partner voluntarily provides his or her Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection.

We will only collect Patient and Partner Personal Information that is necessary to fulfill the following purposes:

  • To verify identity;
  • To identify Patient or Partner preferences;
  • To understand the needs of our Patients or Partners;
  • To deliver requested products, features or services;
  • To provide services;
  • To enroll the Patient or Partner in a program;
  • To contact our Partners for fundraising;
  • To ensure a high standard of service to our Patients and Partners;
  • To communicate with Patients or Partners regarding their registration and customization preferences;
  • To meet regulatory requirements.

We may also collect certain information automatically through cookies and similar tools (see Cookies below).

Cookies

We use cookies and similar tracking technology to track activity on our Site and to hold certain information. We use functional cookies to deliver the desired functionality and user experience, and we use analytics cookies to collect and analyze aggregate visitor behaviour data. Cookies help us better understand how the Site is being used and how to improve it, as well as providing visitors the benefit of not having to re-enter the same data over and over. You can disable cookies, however you if you do so you may not be able to access certain portions of our Site, and we may not be able to customize the Site’s features according to your preferences.

Consent

We will obtain Patient and Partner consent to collect, use or disclose Personal Information (except where, as noted below, we are authorized to do so without consent). Consent can be provided orally, in writing, or electronically, or it can be implied where the purpose for collecting using or disclosing the Personal Information would be considered obvious and the Patient or Partner voluntarily provides Personal Information for that purpose.

Consent may also be implied where a Patient or Partner is given notice and a reasonable opportunity to opt-out of his or her Personal Information being used for mail-outs or the marketing of new services or products, and the Patient or Partner does not opt-out.

Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), Patients or Partners can withhold or withdraw their consent for Eupraxia to use their Personal Information in certain ways. A Patient’s or Partner’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict Eupraxia’s ability to provide a particular service or product. If so, we will explain the situation to assist the Patient or Partner in making the decision.

We may collect, use or disclose Personal Information without the Patient’s or Partner’s knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of Personal Information is permitted or required by law;
  • In an emergency that threatens an individual's life, health, or personal security;
  • When the Personal Information is available from a public source (e.g., a telephone directory);
  • When we require legal advice from a lawyer;
  • For the purposes of collecting a debt;
  • To protect ourselves from fraud;
  • To investigate an anticipated breach of an agreement or a contravention of law.

Using and Disclosing Personal Information

We will only use or disclose Patient or Partner Personal Information where necessary to fulfill the purposes identified at the time of collection. We will not use or disclose Patient or Partner Personal Information for any additional purpose unless we obtain consent to do so. We will not sell Patient or Partner lists or Personal Information to third parties unless we have consent to do so.

Retaining Personal Information

If we use Patient or Partner Personal Information to make a decision that directly affects the Patient or Partner, we will retain that Personal Information for at least one year so that Patient or Partner has a reasonable opportunity to request access to it.
We will retain Patient or Partner Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Ensuring Accuracy of Personal Information

We will make reasonable efforts to ensure that Patient or Partner Personal Information is accurate and complete where it may be used to make a decision about Patient or Partner, or disclosed to another organization. Patients or Partners may request correction to their Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought.
If the Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year. If the correction is not made, we will note the Patients’ or Partners’ correction request in the file.

Securing Personal Information

We are committed to ensuring the security of Patient or Partner Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. The following security measures will be followed to ensure that Patient or Partner Personal Information is appropriately protected:

  • the use of locked filing cabinets;
  • physically securing offices where personal information is held;
  • the use of user IDs, passwords, encryption, firewalls;
  • restricting employee access to personal information as appropriate (i.e., only those that need to know will have access);
  • contractually requiring any service providers to provide comparable security measures.

We will use appropriate security measures when destroying Patients’ or Partners’ Personal Information such as deleting electronically stored information and shredding documents. We will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.

Access to Personal Information

Patients and Partners have a right to access their Personal Information, subject to limited exceptions. A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought. Upon request, we will also tell Patients and Partners how we use their Personal Information and to whom it has been disclosed, if applicable. Eupraxia will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. A minimal fee may be charged for providing access to Personal Information. Where a fee may apply, we will inform the Patient or Partner of the cost and request further direction from the Patient or Partner on whether or not we should proceed with the request. If a request is refused in full or in part, we will notify the Patient or Partner in writing, providing the reasons for refusal and the recourse available to the Patient or Partner.

Children

At Eupraxia, we do not knowingly collect or solicit Personal Information from or about children under 13 except as permitted by law. If we discover we have received any information from a child under 13 in violation of this Privacy Policy, we will delete that information immediately. If you believe Eupraxia has any information from or about anyone under 13, please contact our Privacy Officer at the contact information listed below.

Changes to This Privacy Policy

Eupraxia reviews this Privacy Policy regularly and will place any updates on this page. You are advised to review this Privacy Policy periodically for any changes. This Privacy Policy was last updated on February 9, 2021.

Questions and Complaints

The Privacy Officer is responsible for ensure Eupraxia’s compliance with this Privacy Policy and with PIPA. Patients and Partners should direct any complaints, concerns or questions regarding Eupraxia’s compliance in writing to the Privacy Officer.

Contact information for Eupraxia’s Privacy Officer:

2067 Cadboro Bay Road, #201
Victoria, BC V8R 5G4
(250) 590-3968 ext (504)
privacy@eupraxiapharma.com

If the Privacy Officer is unable to resolve your concern, you may also contact the Office of the Information & Privacy Commissioner of British Columbia.