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Privacy Policy

Effective: October 20, 2015

At Clementia Pharmaceuticals Inc. and its US subsidiary (collectively “Clementia,” “we,” or “us”), we are committed to protecting your private information. This policy (“Privacy Policy”) outlines Clementia’s privacy practices with respect to your personal information. This Privacy Policy applies to any information provided to or collected by Clementia and any collection, use and disclosure of information, including, without limitation, in connection with: clinical trial research study subjects, investigators and other related support personnel; adverse event reporters and subjects; business entities and individuals referenced in contractual documentation and retained in Clementia’s centralized electronic repository of executed agreements; consumers and healthcare professionals making medical inquiries and requesting medical information relating to Clementia’s products; and business entities and individuals processed within certain information technology applications or platforms that support our business functions and which are hosted, supported or maintained by Clementia.

You should to read this Privacy Policy to learn more about the policies and practices that we have developed to safeguard personal and health information, and to better understand our relationships with the third parties who may have access to this information.

Consent to Processing Personal Information in a Different Jurisdiction
Personal Information Collected from our Website
Notice & Collecting Personal Information
Choice & Use of Personal Information
Data Integrity and Disclosing Personal Information
Transfer to Agents
Retaining Personal Information
Access and Ensuring Accuracy of Personal Information
Securing Personal Information
Questions and Complaints
Changes to this policy
Translation Disclaimer
Legal Disclaimer


Consent to Processing Personal Information in a Different Jurisdiction

This site is owned and operated by Clementia in Canada, but the information you provide will be accessible to our affiliates, vendors and suppliers in other countries. Furthermore, if you are visiting this site from a country other than Canada, your communication with us will necessarily result in the transfer of information across international boundaries. The level of legal protection for personal information is not the same in all countries; however, we will take the security measures described in this Privacy Policy in an effort to keep your information secure. By using this site, you consent to the collection, storage, and processing of your information in Canada and in any country to which we may transfer your information in the course of our business operations.


Personal Information Collected from our Website

Clementia respects the privacy of visitors to our Website and only collects personally identifiable information including (but not limited to) your name, address, telephone number, country of residence, email address, and relationship to the Clementia product or program when you voluntarily submit this information by way of the Website. Clementia and/or its third-party business partners (“agents”) will use this information to comply with your request for information, obtain additional information, improve this site, or as otherwise disclosed to you at the time of information submittal. We may use the information to contact you. Except as otherwise set forth in this Privacy Policy, we will not share, sell or transfer your personally identified information to any third party without your explicit consent.


Notice & Collecting Personal Information

Unless the purposes for collecting personal information are obvious and a person voluntarily provides his or her personal information for those purposes, Clementia will communicate about the purposes for which we collect and use personal information, the types of non–agent third parties to which Clementia discloses that information, the choices and means, if any, Clementia offers individuals for limiting the use and disclosure of personal information about them, and how to contact Clementia. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Clementia, or as soon as practicable thereafter, and in any event before Clementia uses or discloses the information for a purpose other than that for which it was originally collected. Where Clementia receives personal information from its subsidiaries or affiliates it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

We may collect, use or disclose personal information without your 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;

When we require legal advice from a lawyer;

To investigate an anticipated breach of an agreement or a contravention of law.

Our Website does not use cookies or any other tracking technology on our visitors’ device and our Website does not respond to “do not track” signals.

We are committed to protecting the privacy of children. We do not knowingly collect personal information from children under age 13 through our Website. If we learn that an individual under the age of 13 has volunteered personal or health-related personal information on the Website, or if you become aware that your child has provided us with personal information without your consent, please contact us at the contact information listed below and such personal information will be deleted.

In order to better serve you, we may automatically collect certain technical information from your computer when you use the Website, such as your IP address, your browser type, your operating system, the sequence or duration of your visits to each Website page and the domain names of our users. We may aggregate this information in order to analyze trends and statistics; however, the aggregated information is not linked to any personally identifiable information that can be used to identify any one individual.


Choice & Use of Personal Information

Clementia will not process personal information about individuals for purposes other than those for which the information was originally obtained or subsequently authorized by the individual unless the individual affirmatively and explicitly consents (“opt-in”) to the processing, or unless an exception applies.

Clementia also provides individuals with the opportunity to withdraw consent at any time (“opt-out”), in which case their personal information will not be further processed. In addition, you may opt out, at any time, in the event that you no longer wish to receive emails from Clementia by unsubscribing from our email list. There are certain limitations on the right to opt-out, such as those that apply in the clinical research situation. In that situation, Clementia can continue to rely upon personal information already provided by clinical research participants who choose to discontinue participation in a clinical trial, to the extent needed to protect the integrity of the study, but cannot collect any additional personal information about that individual once the written request to withdraw participation is received.


Data Integrity and Disclosing Personal Information

Clementia will use or disclose personal information only in ways that are necessary to fulfill the purposes for which it was collected or subsequently authorized by the individual. We will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

If Clementia is involved in a business transaction (such as a sale or merger of all or substantially all of Clementia or a subsidiary), information collected by Clementia, including personal information, as part of the transferred business assets, is subject to the terms of this Privacy Policy and applicable privacy restrictions.


Transfer to Agents

Clementia will obtain assurances from third party business partners (agents) that they will safeguard personal information consistent with Clementia’s policies. In instances where data is transferred to third parties, Clementia will release the minimal amount of identifying data that is necessary for the third parties to complete their responsibilities.


Retaining Personal Information

Clementia will retain personal information only as long as necessary to fulfill the purpose for which such information was collected or as required under applicable laws.


Access and Ensuring Accuracy of Personal Information

Clementia will make reasonable efforts to ensure that personal information is accurate and complete where it may be used. Upon request, Clementia will grant individuals reasonable access to personal information that it holds about them, subject to permitted exemptions. In addition, Clementia will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete, except when the burden or expense of providing access, correction, amendment or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated.


Securing Personal Information

Clementia is committed to ensuring the security of personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks; however, some risk is involved when information is transmitted over the Internet. Clementia cannot guarantee that the Website is completely safe from illegal tampering and you should also recognize that your use of the Internet and this Website is solely at your own risk.

Clementia uses encryption practices to help insure the integrity and privacy of some of the personal and health-related personal information you provide to us. All personal and/or health-related personal information is kept physically behind firewalls that prevent intruders from gaining access. As an added security precaution, Clementia deploys various methods of protection to maintain the integrity and confidentiality of data. Although we will make reasonable efforts to protect personal and/or health-related personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could intercept an internet transmission, or that someone will find a way to violate our security systems.


Questions and Complaints

Any questions, complaints or concerns regarding this Privacy Policy should be directed to Clementia as follows:

Privacy Officer
Clementia Pharmaceuticals Inc.
4150 Ste-Catherine Street West, Suite 550
Montreal, Quebec, H3Z 2Y5
Clementia Pharmaceuticals Inc.
275 Grove Street, Suite 2-400
Auburndale, MA 02466
ATTN: Privacy
Phone: 857-226-5581
Email: privacy@clementiapharma.com


Changes to this policy

We will only use personal information in the manner described in this Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time by posting revisions to our Website. If we make any material changes to this Privacy Policy, we will either notify you or place a prominent notice on our Website. If at any point, we decide to use personally identifiable information or health-related personal information in a manner different from that stated at the time it was collected, you will be given a choice to allow or disallow any additional uses or disclosures of your personally identifiable information or health-related personal information.


Translation Disclaimer

Clementia is making available an automatic translation service that uses state-of-the-art technology, not human translators, to translate text instantly into different languages (“Translation Function”). By providing these translations, Clementia hopes to make essential information available to the diverse populations that visit our Website every day. However, please be aware that, since translations are done by machine, they may not always be perfect. Please see our legal disclaimer at the bottom of this page for additional information.

Translated text may not display property in a particular language if your browser does not have the applicable language pack installed. To download appropriate language packs, visit the website for your browser. If your device is not powerful enough, it is possible that the Translation Function may cause your browser to freeze.

Automatic translation detects patterns in documents that already have been translated by human translators. Using those patterns as a guide, automatic translators are able to make intelligent guesses as to what an appropriate translation should be. Because the translations are generated by machine, not all translations will be perfect. If you encounter a translation that doesn’t seem right, click on the phrase in question – and sometimes the Translation Function will have alternative translation available.


Legal Disclaimer

Clementia provides this link to the Translation Function as a courtesy to visitors to its Website. Clementia does not own, manage or control any aspect of the Translation Function, and is not responsible for the translations provided by the Translation Function. Clementia does not make any promises, assurances, or guarantees as to the accuracy, reliability, or timeliness of the translations provided. Clementia can only verify the validity and accuracy of the information provided in English and, because of this, the English version of our website is the official text. Viewers who rely on information through the Translation Function on our Website do so at their own risk. Clementia shall not be liable for any inaccuracies or errors in the translation and shall not accept liability for any loss, damage, or other problem, including without limitation, indirect or consequential loss or damage arising from or in connection with use of the Translation Function. By using the Translation Function you understand and agree to this disclaimer. If there are any concerns regarding the accuracy of the information presented within the translated versions of our Website, please refer back to the official English- language Website.