PERSONAL INFORMATION AND PRIVACY POLICY

 

 

Last Amended August 30, 2016

The Keystone Labs products and services, including but not limited to:

  • Analytical testing, which includes:
    • Gas Chromatography Analysis;
    • High Performance Liquid Chromatography Analysis;
    • Raw Material Testing;
    • Total Protein Assays;
    • ELISAs;
    • Total Organic Carbon analysis – low level of detection;
    • Nitrates and Heavy Metal analysis;
    • Conductivity and pH analysis;
    • Loss on Drying;
    • Melting Point/Boiling Point; and
    • Identity, purity and quality of raw materials using compendia or client supplied methods;
  • Controlled environment and utilities monitoring, which includes:
    • Total Particulate Monitoring;
    • Viable Particulate Monitoring (surface and air);
    • Full monograph testing of pharmaceutical waters (USP/EP/JP); and
    • Sampling Plan Establishment;
  • Processing water samples to monitor compliance with Pharmacopeial specifications, which includes:
    • Total Organic Carbon;
    • Conductivity;
    • Heavy Metals;
    • Nitrates; and
    • Bacterial Endotoxin;
  • Marijuana testing, which includes:
    • Loss on Drying;
    • Cannabinoid Profile (In-House Method);
    • Delta-9-Tetrahydrocannabinol (THC);
    • Cannabidiol (CBD);
    • Microbial Panel (USP <2023>);
    • Total Aerobic Count;
    • Total Yeast and Mold;
    • Bile Tolerant Gram Negative;
    • Salmonella;
    • Escherichia coli;
    • Chemical Contamination (USP <561>);
    • Aflatoxin B1;
    • Aflatoxin Sum B1+B2+G1+G2;
    • Pesticides; and
    • Heavy Metals (USP <231>);
  • Microbiological testing, which includes:
    • Total Microbial Counts;
    • Microbial Limit Testing;
    • Bacterial Endotoxin Testing;
    • Antimicrobial Effectiveness Testing;
    • Identification of Microorganisms;
    • Alflatoxin Testing;
    • Allergen Testing;
    • Presence/Absence of Objectionable Microorganisms;
    • Total Aerobic Counts and Total Yeast and Mold;
    • Disinfectant Testing;
    • Sterility Testing:
      • Membrane Filtration; and
      • Direct Transfer;
    • USP validation;
    • Cell Banking:
      • Preparation of cell banks; and
      • Purity and viability testing; and
    • Method development and validation, which is:
      • Carried out by qualified personnel equipped with adequate resources;
      • Designed to obtain the range and accuracy relevant to the client’s needs;
      • Handled by utilizing a protocol or plan agreed upon by both the client and by Keystone Labs;
      • Communicated effectively and efficiently between Keystone Labs and the client; and
      • Summarized in a final report that will be signed off by both the client and Keystone Labs;

(collectively, the “Services”) and platform, including any related software, apps, websites and associated services, (collectively, the “Platform“), are provided, owned and/or operated by Keystone Labs Inc. (“Keystone Labs”). The Services and the Platform shall include any new products, services or client interface mechanisms, which may be added from time to time. This page states the Personal Information and Privacy Policy by which Keystone Labs and users of the Services and the Platform abide (“Privacy Policy”). This Privacy Policy applies if you access the Platform through any device, including but not limited to a smart phone, tablet, laptop or desktop computer, or though any other means.

Keystone Labs has created and implemented this Privacy Policy so that you understand how your personal information may be collected, retained, used, disclosed and destroyed and how it is protected by Keystone Labs. Keystone Labs encourages you to review this Privacy Policy.

This Privacy Policy covers:

  • The information collected by Keystone Labs;
  • How Keystone Labs collects, retains, uses, discloses, destroys and protects your personal information;
  • Certain of your options and obligations as a user of the Services and the Platform;
  • Your requests to access or correct your personal information; and
  • How to contact Keystone Labs.

By providing personal information while using the Services or the Platform and dealing with Keystone Labs, you consent to the collection, retention, use, disclosure, destruction and protection of your personal information in accordance with the terms set out in this Privacy Policy.

Should you have questions regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer using the contact information provided at the end of this Privacy Policy.

Compliance with Legislation

Keystone Labs is compliant with the federal Personal Information Protection and Electronic Documents Act, SC 2000, c 5 (“PIPEDA”) and other privacy legislation which may apply from time-to-time, which are designed to protect your personal information and privacy. Keystone Labs primarily has based this Privacy Policy on the principles set out in PIPEDA.

Our Commitment to Your Privacy

Keystone Labs is committed to protecting your personal information and privacy and considers matters relating to the protection of your personal information and privacy to be of the utmost importance. Keystone Labs adheres to the following principles to protect your privacy:

  • Keystone Labs does not sell, rent, loan, trade, lease, transfer or otherwise disclose your personal information to third parties, except as otherwise provided in this Privacy Policy or as permitted or required by law.
  • Keystone Labs does not share any information which you have not chosen to display on the Platform to third parties, unless required by law or as necessary to enforce Keystone Labs’ terms of use or to protect the rights, property or personal safety of the Keystone Labs, its members and the public.
  • All information which you provide to Keystone Labs will be protected with industry-standard protocols and technology.

Definitions

Unless otherwise provided in this Privacy Policy, the terms used herein shall be defined as in PIPEDA where applicable. In this Privacy Policy, the following term has the following meaning:

  • personal information” means information about an identifiable individual.  Personal information does not include information that cannot be attributed to you an identifiable individual, such as information of an aggregate or anonymous nature.

Changes to this Privacy Policy

Keystone Labs may amend this Privacy Policy at any time by posting a new privacy policy on the Platform in place of this one. The date on which the Privacy Policy was last amended is indicated at the start of this Privacy Policy. The amended Privacy Policy shall automatically be effective when posted. Amendments may include, without limitation, additions, deletions or modifications to this Privacy Policy.

Keystone Labs will post notice that the Privacy Policy has been amended on the fronting webpage of the Platform located at www.keystonelabs.ca for a period of 30 days. You are advised to check for such notices and to review the Privacy Policy each time you use the Services or the Platform in order to ensure that you are aware of any amendments and that they are acceptable to you.

Your continued use of the Services or the Platform following the posting of an amended Privacy Policy and the related notice means that you accept the terms of this Privacy Policy as amended. If you do not agree with any of the terms or conditions in the amended Privacy Policy, then you agree to immediately cease all use of the Services or the Platform, which shall be your sole recourse and remedy in the event you are dissatisfied with the amended Privacy Policy. This Privacy Policy may not otherwise be amended.

Personal Information Aggregated or Made Anonymous

To the extent that Keystone Labs makes any of your personal information anonymous or aggregates it with the personal information of others such that it can no longer be attributed to you, your information will no longer be considered to be personal information and Keystone Labs is entitled to use, retain, disclose and destroy such information in its absolute discretion.

Choosing to Provide Personal Information

When using the Services or the Platform and dealing with Keystone Labs, you may choose not to provide certain of your personal information. If you choose not to provide all information reasonably requested of you, it may limit the manner in which you can make use of the Services or the Platform and otherwise interact with Keystone Labs or you may not be able to use the Services or the Platform or to interact with Keystone Labs at all.

Consent

By using the Services or the Platform, you provide implied consent to the collection, retention, use, disclosure, destruction and protection of your personal information by Keystone Labs in accordance with the terms of this Privacy Policy. Your implied consent may be obtained through amendments to this Privacy Policy, as provided above.

Keystone Labs will obtain your express consent prior to or when collecting, using or disclosing your personal information in cases of sensitive information, for a purpose that is not described in this Privacy Policy, or for a purpose that Keystone Labs did not identify to you or that was not reasonably expected at the time of collection, unless Keystone Labs is required or authorized by law not to obtain your consent.

You provide implied consent to the collection, retention, use, and disclosure of your personal information for a particular purpose if you voluntarily provide the information to Keystone Labs for that particular purpose and it is reasonable that a person would voluntarily provide that information.

In certain circumstances, including but not limited to when dealing with certain legal, medical or security issues, Keystone Labs may be authorised or required by law to disclose your personal information without seeking or obtaining your knowledge or consent.

Consent via Opt-In or Opt-Out in Certain Circumstances

Keystone Labs may, from time to time, provide you with a reasonable opportunity to opt-out of certain collections, uses and disclosures of your personal information. You implicitly consent to a particular collection, use or disclosure your personal information if you fail to indicate within a reasonable time that you wish to opt out of the particular collection, use or disclosure when you are given a reasonable opportunity to do so.

Keystone Labs also may, from time to time, provide you with a reasonable opportunity to opt-in to certain collections, uses and disclosures of your personal information.  If you do not opt-in to a particular collection, use or disclosure your personal information when given a reasonably opportunity to do so, you do not consent to your personal information being collected, used or disclosed in that particular manner.

Where the Keystone Labs provides an opt-in or opt-out opportunity, Keystone Labs will use the opt-out method when the particular collection, use or disclosure does not pertain to sensitive information or would be reasonably expected by the user of the Services or the Platform. Keystone Labs will use the opt-in method in other circumstances.

Changing or Withdrawing Consent

You may change or withdraw your consent with respect to the collection, retention, use, disclosure, destruction and protection of your personal information in accordance with this Privacy Policy at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer using the contact information provided at the end of this Privacy Policy and by providing Keystone Labs with sufficient personal identifiers so that Keystone Labs  can act effectively on your request.

If you withdraw certain consents reasonably requested of you and necessary for you to make use of the Services or the Platform or to otherwise interact with Keystone Labs, it may limit the manner in which you can make use of the Services or the Platform and otherwise interact with Keystone Labs or you may not be able to use the Services or the Platform or interact with Keystone Labs at all.

Your ability to change or withdraw consent is not absolute. Keystone Labs reserves the right to continue handling your personal information in those circumstances required or permitted by law despite a change or withdrawal of consent.

Any change to or withdrawal of consent will not apply retroactively.

Collection of Personal Information

Most of the personal information about you that Keystone Labs collects will be collected directly from you by Keystone Labs. Except as otherwise provided in this Privacy Policy, Keystone Labs will obtain your consent to collect your personal information and will inform you at that time of the uses and disclosures that Keystone Labs intends to make of your personal information, unless the intended uses and disclosures are described in the Privacy Policy or are reasonably expected at the time that Keystone Labs collects your personal information.

In some instances, Keystone Labs may collect your personal information directly from a third party, in which case Keystone Labs will obtain your consent to such collection unless required or permitted by law not to obtain your consent or unless the third party provided confirmation to Keystone Labs that it is entitled by law to disclose your personal information to Keystone Labs.

Use of Personal Information

When Keystone Labs uses your personal information, it will ensure that you previously provided consent to the intended use or it will obtain your consent prior to using your personal information in that particular manner, unless the intended use is described in this Privacy Policy, was identified to you or was reasonably expected at the time that Keystone Labs collected your personal information, or is permitted or required by law without your consent.

The following are particular circumstances in which Keystone Labs may use your personal information without obtaining your further consent. By providing your personal information to Keystone Labs, you consent to the following uses:

  • using identification information and contact information, such as your name, address and e-mail address, to provide you with information about Keystone Labs when you request that information;
  • using identification information and contact information, such as your name, address and e-mail address, so that Keystone Labs can identify you and deliver the Services that you request and to communicate with you regarding those Services;
  • using payment method preferences and related financial information that you provide to Keystone Labs so that Keystone Labs can obtain payment for the Services that you request;
  • using information relating to your preferences so that Keystone Labs can deliver the Services and the Platform to you in accordance with those preferences;
  • using customer relationship information such as your service requests, instructions, comments and feedback to assist Keystone Labs in delivering the Services and the Platform in accordance with your preferences;
  • using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose;
  • using your e-mail address to provide you with information about new features or enhancements to the Services or the Platform;
  • analyzing your personal information to assist Keystone Labs in developing and enhancing the Services or the Platform; and
  • analyzing your personal information to assist Keystone Labs in conducting market analysis and strategic planning.

Disclosure of Personal Information

When Keystone Labs discloses your personal information, it will ensure that you previously provided consent to the intended disclosure or it will obtain your consent prior to disclosing your personal information in that particular manner, unless the intended disclosure is described in this Privacy Policy, was identified to you or was reasonably expected at the time that Keystone Labs collected your personal information, or is permitted or required by law without your consent.

The following are particular circumstances in which Keystone Labs may disclose your personal information without obtaining your further consent. By providing your personal information to Keystone Labs, you consent to the following disclosures:

  • where the disclosure is set out in the related documentation for the Services or the Platform or is reasonably expected through the provision of the Services or the operation of the Platform;
  • where disclosure is necessary to enable staff, employees, agents, contractors, suppliers, affiliates or partners of Keystone Labs to provide a product or service to Keystone Labs or to you and  to perform a function on behalf of Keystone Labs. Keystone Labs will act in a reasonable manner, including by contractual or other means, to ensure that these individuals or entities collect, use and disclose your personal information only as necessary to provide the product or service or to perform the function, adhere to this Privacy Policy or to their own comparable privacy policy, and comply with applicable  privacy legislation with respect to your personal information, but Keystone Labs cannot guarantee these individuals’ or entities’ compliance;
  • where Keystone Labs is under a duty to disclose your personal information in order to comply with any applicable legal obligation, legal or regulatory process  or an order or request of a government institution, investigative body, regulatory body or judicial authority of competent jurisdiction;
  • where Keystone Labs believes in good faith that disclosure is necessary:
    • to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies or investigative bodies in that regard;
    • to enforce agreements to which Keystone Labs is a party;
    • to investigate and defend Keystone Labs against any third party claims or allegations;
    • to protect the security or integrity of the Services or the Platform;  and/or
    • to exercise or protect the rights, property or personal safety of Keystone Labs, its clients and users, employees, or others;
  • where Keystone Labs transfers or is considering transferring control of any or all of its assets, operations or services, including its rights and obligations relating to the Services or the Platform, to a third party. The third party may continue to retain and use the personal information which you provided to Keystone Labs. Keystone Labs will act in a reasonable manner, including by contractual or other means, to ensure that the third party agrees to similarly be bound by this Privacy Policy and to similarly comply with applicable privacy legislation with respect to your personal information, but Keystone Labs cannot guarantee the third party’s compliance;
  • where Keystone Labs amalgamates with a third party. The amalgamated entity may continue to use and disclose your personal information. Keystone Labs will act in a reasonable manner, including by contractual or other means, to ensure that the amalgamated entity agrees to similarly be bound by this Privacy Policy and to similarly comply with applicable privacy legislation with respect to your personal information, but Keystone Labs cannot guarantee the amalgamated entity’s compliance; and
  • where Keystone Labs works with one or more organizations towards a common purpose consistent with the objectives of Keystone Labs. Keystone Labs will act in a reasonable manner, including by contractual or other means, to ensure that these organizations collect, use and disclose your personal information only as necessary for the common purpose, adhere to this Privacy Policy or to their own comparable privacy policy, and comply with applicable privacy legislation with respect to your personal information, but Keystone Labs cannot guarantee these organizations’ compliance.

Use of the Platform

In order to use some of the features of the Platform, Keystone Labs may require that you provide some personal information.

Keystone Labs’ web servers collect the domain names, IP addresses and the activity of visitors.  This information is aggregated for the purposes of measuring the number of visits, average time spent on the Platform, pages viewed, and other similar purposes. Keystone Labs uses this information to measure the use of the Platform and to improve the content of the Platform.

Cookies

Cookies may be used on certain pages of the Platform.  A “cookie’ is small piece of data that resides on your computer, smart phone, tablet or other device that you use to access the Internet. It is sent by a website to be stored on a visitor’s Internet browser so that it can be recognized by the website to identify the visitor on subsequent visits to the website from the same device and Internet browser. Keystone Labs may use cookies to track visitors’ usage of the Platform and to provide visitors with tailored information and services on the Platform based on their previous visits. Cookies do not enable Keystone Labs to identify the visitor unless that visitor has previously provided personal information during a visit.

If your browser permits, you may adjust the settings of your Internet browser to notify you when you receive a cookie or to reject cookies altogether, but in some cases doing so may impact your ability to use the Platform. Because each Internet browser is different, users of the Platform should check the “help” menu of their browsers to learn how to change their cookie preferences.

Other Collection, Use and Disclosure of Personal Information

Keystone Labs may monitor your use of the Platform to ensure the proper use and operation of the Platform and your compliance with any agreements and terms of use for the Platform.

Keystone Labs also reserves the right to collect, use and disclose your personal information without your knowledge or consent where permitted or required by law.

Accuracy and Completeness of Personal Information

When Keystone Labs collects, uses or discloses personal information, it will make a reasonable effort to ensure that the personal information is accurate, up-to-date, and complete to the extent that is reasonable for Keystone Labs’ purposes in collecting, using or disclosing the information. To do so, it may be necessary for Keystone Labs to request additional information from you or have you verify your personal information. Should your personal information change, please inform Keystone Labs of the change(s) so that your personal information in Keystone Labs’ possession remains accurate and complete.

Retention and Destruction of Personal Information

Keystone Labs may retain your personal information for as long as it reasonably requires your personal information for the purposes for which it was collected or for legal or business purposes. There are legally required minimum retention periods which Keystone Labs must and does observe. Keystone Labs will retain your information for as long as reasonably necessary to comply with its legal obligations, to resolve disputes, and to enforce this Privacy Policy and any terms of use.

Within a reasonable time period after Keystone Labs no longer reasonably requires your personal information for the purposes for which it was collected or for legal or business purposes, Keystone Labs either will destroy the records under its custody or control containing your personal information or it will render your personal information anonymous so that it can no longer be used to identify you.

Security of Personal Information

Keystone Labs recognizes its obligation to protect personal information that is in its custody or under its control by implementing reasonable security safeguards to keep confidential and secure your personal information against risks such as loss, theft, and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. These reasonable safeguards may vary depending on the circumstances, including the level of sensitivity of the personal information, and may include restricting access to authorized individuals on a need-to-know basis, locked doors and/or filing cabinets, other organizational, physical or technological security measures, and contractual measures such as non-disclosure or confidentiality agreements.

As previously described in this Privacy Policy, Keystone Labs will act in a reasonable manner, including by contractual or other means, to require third parties to whom Keystone Labs discloses your personal information in accordance with this Privacy Policy or as required or permitted by law to similarly safeguard your personal information by abiding by this Privacy Policy or their own comparable privacy policies and by complying with applicable privacy legislation with respect to your personal information. However, Keystone Labs cannot guarantee such compliance by third parties.

Requests for Access to Personal Information

Requests for Personal Information

On your written request, and taking into consideration what is reasonable, Keystone Labs will provide you, not later than 30 days from Keystone Labs’ receipt of your request, or such additional time as permitted or required by law, with:

  • access to your personal information (if any) under our custody or control;
  • information about the purposes for which your personal information (if any) under our custody or control has been and is being used by us; and
  • the names of persons to whom, and the circumstances in which, your personal information (if any) has been and is being disclosed by us.

If you request a copy of your personal information and the information can reasonably be reproduced, Keystone Labs will provide you with a copy of the record or the part of the record containing the requested information or, if applicable, it will give you reasons for any delay in providing a copy of the requested information or record.

If you request to examine the record containing your personal information or if the requested record cannot reasonably be reproduced, Keystone Labs will permit you to examine or access the record or part of the record in accordance with this Privacy Policy.

All requests may be subject to reasonable fees and disbursements. Where appropriate, Keystone Labs may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.

Requests to Access Personal Information must be in Writing

Keystone Labs requires that all requests for access to personal information be in writing, be signed by the requestor and include sufficient detail to enable Keystone Labs, with a reasonable effort, to identify any record in the custody or under the control of Keystone Labs containing the personal information in respect of which the request is made

Limits on Right to Access Personal Information

Your ability to access your personal information under Keystone Labs’ custody and control is not absolute. Keystone Labs reserves all rights not to disclose personal information, in whole or in part, in certain circumstances permitted or required by law, including but not limited to where:

  • the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual;
  • the disclosure would reveal personal information about another individual;
  • the information is protected by any legal privilege;
  • the disclosure of the information would reveal confidential commercial information; or
  • the personal information was collected for an investigation or legal proceeding.

If access to your personal information is refused, in whole or in part, Keystone Labs will provide you with the reasons for the refusal, the provision of PIPEDA on which the refusal is based, and the name of the individual who can answer your questions on behalf of Keystone Labs about the refusal, and will inform you of any recourse which you may have pursuant to PIPEDA.

Requests for Correction of Personal Information

On written request by you, Keystone Labs will make every reasonable effort to correct errors or omissions in your personal information where that information is in Keystone Labs’ custody or control. Keystone Labs requires that all such requests be in writing, be signed by the requestor, and include sufficient detail to enable Keystone Labs, with a reasonable effort, to identify any record in the custody or under the control of Keystone Labs containing the personal information in respect of which the request is made.

If you make such a request, Keystone Labs will, as soon as reasonably possible and not later than 30 days from Keystone Labs’ receipt of your request, or within such additional time as permitted or required by law, either:

  • correct the personal information and, if reasonable to do so, send correction notifications to any third party to whom Keystone Labs disclosed the incorrect information; or
  • decide not to correct the personal information, but Keystone Labs will annotate the personal information under its control to indicate that a correction was requested but not made.

Keystone Labs will inform you of the action that it has taken in response to your request for correction, the name of the individual who can answer your questions on behalf of Keystone Labs about your request for correction, and will inform you of any recourse which you may have pursuant to PIPEDA.

Notwithstanding any requests for corrections of personal information, Keystone Labs will not correct or otherwise alter an opinion, including a professional or expert opinion.

Limited Nature of this Privacy Policy

Nothing contained in this Privacy Policy is intended to create a contract or agreement between Keystone Labs and you and you may not rely on it as such.

Accountability and Contacting Keystone Labs

Keystone Labs has designated a Privacy Officer to respond to any complaints or inquiries with regards to how Keystone Labs handles your personal information. The Privacy Officer is responsible for overseeing Keystone Labs’ compliance with this Privacy Policy, PIPEDA and other privacy legislation which may apply from time-to-time.

Should you have any questions or comments regarding Keystone Labs’ privacy policies, practices, or handling of your personal information or if you wish to request access to or correction of your personal information under Keystone Labs’ care and control, you may contact Keystone Labs’ Privacy Officer at:

Attention: Privacy Officer
Address: 7225 Roper Road NW
Edmonton, AB
Canada
T6B 3J4
email: key@keystonelabs.ca