Privacy Policy

At Clementia Pharmaceuticals Inc. including all of its subsidiary companies (collectively “Clementia,” “we,” or “us”) we are committed to safeguarding your privacy when using our Website at www.clementiapharma.com.

References in this Privacy Policy to Personal Data refer to any information relating to an identified or identifiable natural person such as but not limited to Your contact details (first name, last name, address, e-mail address, fax, telephone), IP address, curriculum vitae, and any other data that can be used to identify You.

This Privacy Policy applies to any data provided to or collected by Clementia and any collection, use and disclosure of data, 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 data relating to Clementia’ s products; and business entities and individuals processed within certain data technology applications or platforms that support our business functions and which are hosted, supported or maintained by Clementia.

The type of Personal Data we collect and process about You and which will differ depending upon our relationship include contact details, government and other official identification numbers (social security number, tax identification number), professional information (company, title/function), health and medical information, financial information and account details, curriculum vitae, photographs, online activity information and any additional information from other sources. We will hold different types of Personal Data if You are a patient, a healthcare provider, a vendor, a supplier, a client, a prospective client, an applicant or a visitor to our Website.

If Clementia is involved in a business transaction (such as a sale, joint-venture, merger, transfer or other transaction), any Personal Data collected by Clementia as part of transferred business assets will be subject to the terms of this Privacy Policy and applicable privacy restrictions.

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

Personal Data Collected from our Website

Clementia respects the confidentiality and privacy of visitors to its Website and only collects personally identifiable data that You may choose to voluntarily provide including but not limited to your name, address, telephone number, country of residence, email address, health data in connection to a Clementia product or program.

By requesting information through the Clementia Website, such as information regarding Clementia products and services, You will have to expressly consent to Clementia’ s use of your Personal Data to respond to your request, including by sharing it with third parties if necessary or appropriate for such purpose. We may use the data to contact You. Except as otherwise set forth in this Privacy Policy, we will not share, sell or transfer your personally identified data to any third party without your explicit consent.

We are committed to protecting the privacy of children. We do not knowingly collect Personal Data 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 Data on the Website, or if You become aware that your child has provided us with Personal Data without your consent, please contact us at the contact data listed below and such Personal Data will be deleted.

Purposes of Personal Data Processing

Unless the purposes for collecting Personal Data are obvious and a person voluntarily provides his or her Personal Data for those purposes, Clementia will communicate about the purposes for which it collects and use Personal Data, the third parties to which Clementia may disclose such data, the choices and means, if any, Clementia offers individuals for limiting the use and disclosure of their own Personal Data, and how to contact Clementia with any concerns. Clementia will not process Personal Data about individuals for purposes other than those for which the data was originally obtained or subsequently authorized by the individual unless the individual affirmatively and explicitly consents to the processing, or unless an exception applies.

When seeking your consent, we will inform You in clear and conspicuous language when You are first asked to provide Personal Data to Clementia, or as soon as practicable thereafter, and in any event before Clementia uses or discloses the data for a purpose other than that for which it was originally collected. Where Clementia receives Personal Data from its subsidiaries or affiliates it will use and disclose such data in accordance with the consent obtained by such entities and the choices made by the individuals to whom such Personal Data relates.

We may collect, use or disclose Personal Data without your knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of Personal Data is permitted or required by law or in response to valid requests by public authorities;
  • In an emergency that threatens an individual’s life, health, or personal security;
  • When we have a legitimate business interest in doing so, which will generally consist in the pursuit of our business activities and commercial objectives, the protection of our business, partners, the improvement or further development of our services and business operations and the compliance with legal and regulatory obligations, standards, guidelines and codes of conduct.

Our Website does not use cookies or any other tracking technology on our visitors’ device. Clementia only uses essential cookies that are strictly necessary for the operation of our Website. They include, for example, cookies that enable basic functions such as page navigation and access to secure areas of our Website.

Sharing and cross border transfer of your Personal Data

This site is owned and operated by Clementia in Canada, but the Personal Data You provide will be accessible to our affiliates and may also be shared with third parties. These third parties may include (i) external third party outsourced service providers, vendors or business partners that assist us in carrying out our business activities (“third party agents”) and (ii) other unaffiliated third parties which do not act as agents or service providers and are not performing functions on our behalf (e.g. purchasers and prospective purchasers or other parties in any proposed reorganization, sale, joint-venture, merger, transfer or other transaction relating to our business, assets, companies or stock).

Clementia will release the minimal amount of data that is necessary for these third parties to perform their contractual obligations and Clementia shall obtain assurances in writing that they will safeguard Personal Data and provide the same level of protection for Personal Data Clementia Privacy Policy and applicable law require. Clementia takes reasonable and appropriate steps to ensure that third-party agents process Personal Data in accordance with its Privacy Policy and to stop and remediate any authorized processing. Clementia will not provide your Personal Data to unaffiliated third parties without your knowledge and consent.

Furthermore, if You are visiting this site from a country other than Canada, any information You provide to us through use of this Website will necessarily result in the transfer of your Personal Data across international boundaries. The level of legal protection for Personal Data is not the same in all countries and may differ from the one in which You reside. However, we will handle your Personal Data in accordance with this Privacy Policy in an effort to keep your data secure and take steps to ensure that your Personal Data is protected with the same level of protection required by applicable law.

To that end, Clementia USA has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles regarding the collection, use and retention of personal information transferred from the EU to the US.

Individual Rights

If You have given your consent to the processing of your Personal Data, Clementia provides You with the right to withdraw that consent at any time, without such withdrawal affecting the lawfulness of processing based on consent before its withdrawal.

Clementia will make reasonable efforts to ensure that Personal Data is accurate and complete where it may be used. Upon request, Clementia will grant You reasonable access to your Personal Data that it holds about You and take reasonable steps to permit You to correct, amend, restrict, object or delete data that is demonstrated to be inaccurate or incomplete or no longer necessary in relation to the purposes for which they were collected. These access rights may not apply in some cases including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access.

Retaining Personal Data

Clementia will retain Personal Data only as long as necessary to fulfill the purpose for which such data was collected or as necessary for compliance with a legal obligations to which Clementia is subject, or in order to protect your vital interests or the vital interests of another natural person.

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.

Securing Personal Data

Clementia is committed to ensuring the security of Personal Data in order to protect it from unauthorized access, unlawful processing or disclosure, as well as accidental loss, modification or destruction.

To this end, Clementia uses technical, administrative and procedural measures in an attempt to safeguard your Personal Data. It includes the use of encryption practices to help insure the integrity and privacy of the personal and health-related Personal Data You provide to us. Equally, all personal and/or health-related Personal Data is kept physically behind firewalls that prevent intruders from gaining access. Nevertheless, while we will make reasonable efforts to protect personal and/or health-related Personal Data, You should be aware that there is always some risk that an unauthorized third party could intercept an internet transmission and, we do not guarantee that your Personal Data will be secure from accidental loss, unauthorized access, improper use or disclosure.

Questions and Complaints

Any questions, complaints or concerns regarding this Privacy Policy should be directed to Clementia using the contact details below:

Privacy Officer
Clementia Pharmaceuticals Inc.
4150 Ste-Catherine Street West, Suite 550
Montreal, Quebec, H3Z 2Y5
Email: privacy@clementiapharma.com

Clementia Pharmaceuticals USA Inc.
275 Grove Street, Suite 2-400
Auburndale, MA 02466
ATTN: Privacy
Email: privacy@clementiapharma.com

For European residents, please send your email to DPO@mydata-trust.com.

Changes to this policy

We will only use Personal Data in the manner described in this Privacy Policy in effect when the data was collected from You. However, we reserve the right to update the terms of this Privacy Policy from time to time so please check it regularly. 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 data or health-related Personal Data 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 data or health-related Personal Data.

Translation Disclaimer

Clementia does not offer translation services through its Website. No liability is assumed by Clementia for any errors, omissions, or ambiguities in translations provided by third party translators or translation software or services of the Clementia Website. Only the English version of our Website is the official text. Any person or entity that relies on translated content does 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. If there are any concerns regarding the accuracy of the data presented within the translated versions of our Website, please refer back to the official English-language Website.