Privacy Policy

Effective Date: June 2, 2026

1| WHO WE ARE

This Privacy Policy (“Policy”) describes how Vital - Canada’s Pharmaceutical Supply Chain Alliance (“Vital”, “we”, “us”, “our”) collects, uses, and shares personal information through its bilingual website and member portal <https://vital.ca> (collectively, “website”). We are committed to protecting the privacy of our members, event participants, and website visitors in accordance with applicable Canadian privacy laws.

2| SCOPE

This Policy applies to the website served in English and French from the operator’s primary domain, including:

  • public pages (news, events, advocacy, member directory);
  • the member portal (gated content reserved for authenticated members);
  • forms hosted on the website (event registration, login, account creation, password reset, and contact and inquiry forms).

Our website is intended for professionals in the pharmaceutical supply chain industry; it is not directed at children.

3| DEFINITION OF PERSONAL INFORMATION 

In this Policy, “personal information” refers to any information which could be used alone or in combination with other information to directly or indirectly identify an individual. This may include, for example, your name, contact information, address, and email address. It may also include more technical information, such as your IP address, browser settings, and device ID, but only when this information can identify you as an individual.

4| PERSONAL INFORMATION WE COLLECT

We limit the collection of personal information to what is necessary to fulfill the purposes identified in this Policy.  We may collect the following personal information about you depending on your interactions with us (for instance, if you are a member, an event customer, or a website visitor):

4.1| Information you provide when you create an account or are added by a member administrator:

This may include:

  • first name and last name;
  • email address;
  • a password (stored only as a hashed value, never in clear text);
  • optional phone number;
  • optional affiliation with a member organization (company name and title).

4.2| Information you provide when you register for an event:

This may include:

  • the answers you submit through the registration form attached to that event. The fields vary by event, but typically include full name, email address, organization or company name, phone number, event registration details, and billing information; 
  • some events may ask for additional information chosen by the event organizer (for example, dietary preferences or whether you wish to participate in an associated activity such as a golf tournament). Only the fields displayed in the form are collected.

4.3| Information collected automatically when you visit the website:

  • IP address and user-agent string, recorded in standard server access logs;
  • session cookies issued after you log in (see Section 7);
  • if web analytics is enabled, the events captured by Google Tag Manager and Google Analytics (see Section 6).

5| HOW WE USE YOUR INFORMATION

We may use the information described above for the following purposes or otherwise, with your consent or as permitted or required by law:

  • general business purposes such as providing or delivering a product or service requested, managing our business, responding to your inquiries, meeting our contractual, legal, and regulatory obligations as well as for purposes relating to information, system, or network security;
  • create and manage your account, authenticate you, and keep you signed in;
  • process event registrations, including building the guest list for each event and issuing invoices for an event and when it is paid;
  • send transactional emails to communicate related to your account or your registrations (account activation, password reset, registration confirmation, payment notification, calendar invitation);
  • deliver member-only content and downloads to authenticated members;
  • protect the website against automated abuse on the login, registration, password-reset, and contact forms;
  • keep public content searchable on the website;
  • operate, secure, and improve the website;

We do not sell your personal information.

We do not use your information for automated decision-making that produces legal or similarly significant effects.

6| THIRD PARTIES THAT PROCESS YOUR INFORMATION ON OUR BEHALF

We may share your personal information with our members and service providers (companies that carry out activities on our behalf), and in the context of a sale or transfer of our business or similar transaction. We may also share your personal information with your consent or in accordance with applicable law.

6.1| Members

Your member information (i.e., status as a member) may be shared with other members with whom we work and/or that use our products, to the extent permitted by law.

6.2| Service Providers 

We may share personal information with our agents, vendors, or other organizations that provide services on our behalf, for the purposes set out in this Policy. These service providers help us operate and manage our website, event registration, information systems, infrastructure, and marketing. They provide services to us, such as email communications, event registration and invoices, transactional email delivery, data hosting, and analytics services (e.g., analyzing usage of our website). 

When Vital shares personal information with its service providers, we ensure by contractual means that the transferred personal information is used only for the purposes for which the service provider is retained and is protected to the same degree as it is when in our possession. Our service providers may be located around the world, as further detailed in the International data transfers section below (see Section 8).

6.3| Sale or Transfer or other Transaction

We may decide to sell or transfer all or part of our business to a third party, merge with another entity, secure our assets, or proceed with any other financing or other strategic capital transactions (including insolvency or bankruptcy proceedings), restructuring, share sale or other change in corporate control. We may share your personal information when required for the purposes of such a transaction in compliance with applicable laws.

6.4| Other Permitted Purposes 

We may share your personal information when permitted or required by applicable law, for instance:

  • With governmental authorities, law enforcement, and courts when compelled by law; and
  • For the purposes of detecting or suppressing fraud or criminal activity, protecting our assets and interests, conducting an internal or external investigation into any actual or suspected illegal activity or managing, defending, or settling any actual or potential loss in connection with the foregoing.

7| COOKIES AND SIMILAR TECHNOLOGIES

The website sets the following categories of cookies. Our website uses cookies and similar technologies to improve website functionality, analyze website traffic and usage patterns, and enhance the user experience.

7.1| Strictly necessary cookies (always set, cannot be disabled while you use the website):

These cookies are required for the operation of a website and cannot be disabled in our systems.

7.2| Analytics cookies (set only when web analytics is enabled by the operator):

These cookies are used to provide visitors with customized experiences based on the pages you visited previously and to analyze the effectiveness of the webpages.

Google Tag Manager and Google Analytics may set cookies. When enabled, these collect standard web-analytics signals (pages viewed, approximate location based on IP, device and browser characteristics, referring URL). These cookies record anonymous usage information.

8| INTERNATIONAL DATA TRANSFERS

Several of the sub-processors listed in Section 5 are headquartered outside Québec and outside Canada. When you use the website, some of your personal information will therefore be processed in the United States or in other jurisdictions. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts, and law enforcement in that jurisdiction. 

9| HOW LONG WE KEEP YOUR INFORMATION

We store your personal information for as long as necessary to respond to your inquiry, to manage our business operations, and to comply with our legal and regulatory obligations. Once no longer required, your personal information will be securely destroyed in accordance with legal requirements.

10| HOW WE PROTECT YOUR INFORMATION

Vital maintains appropriate policies and practices aimed at safeguarding your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:

  • A privacy framework governing the protection of personal information through its lifecycle. This framework defines the roles and responsibilities of Vital’s employees, provides a process for dealing with complaints regarding the protection of the information, and addresses the retention and destruction of personal information.
  • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis.
  • Industry-standard technical measures, including:
    • encryption in transit (HTTPS) for all requests to the website;
    • hashing of passwords using Craft CMS’s default password-hashing algorithm; passwords are never stored or transmitted in clear text;
    • HTTP-only cookies for authentication tokens, so they cannot be read by client-side scripts;
    • captcha challenges (Cloudflare Turnstile) on the login, registration, password-reset, and contact/registration forms;
    • access controls on member-only files: private files are served only after the user’s JSON Web Token or control-panel session has been verified;
    • no storage of payment card data on our infrastructure — card details are entered directly on QuickBooks-hosted payment pages operated by Intuit.
  • A designated Privacy Officer to monitor Vital’s compliance with applicable privacy laws.
  • Employee privacy and data security training.

No method of electronic transmission or storage is completely secure. If we become aware of a confidentiality incident affecting your personal information, we will act in accordance with applicable law.

11| YOUR RIGHTS

Subject to the conditions set out in applicable Canadian privacy law, you may have the right to:

  • access the personal information we hold about you;
  • ask us to correct information that is inaccurate or incomplete;
  • ask us to delete your account and the information attached to it;
  • ask for a copy of your information in a structured, commonly used format;
  • withdraw the consent you have given for a specific use, where the processing is based on consent.


To exercise any of these rights, contact us at privacy@vital.ca. 

12| CHILDREN

The website is intended for professionals in the pharmaceutical supply chain industry. It is not designed for, marketed to, or knowingly used by children under the age of 14. We do not knowingly collect personal information from children. If you believe a child has provided personal information through the website, please contact us privacy@vital.ca and we will delete it.

13| CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in how the website works or changes in applicable law. When we do, we will revise the “Effective date” at the top of the webpage. Material changes will be highlighted on the home page or communicated by email to active members.

14| CONTACT

Questions, requests, or complaints about this Policy and how we process your personal information can be sent to our Privacy Officer at: 

 

Vital - Canada’s Pharmaceutical Supply Chain Alliance
PO Box 76006
Oakville, Ontario
L6M 3H5
T: (905) 265-1706 
E: privacy@vital.ca

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