Medison Website Privacy Policy

Medison Pharma Group (“Medison” or “we” or “Our”) is committed to maintaining the privacy of its users. This privacy policy (“Privacy Policy”) governs how we, Medison, are committed to maintaining the privacy of its users. The following information describes how Medison collects and processes personal information from or about you When you visit or interact with our website or other web platforms GISTXpress.ca, (“Website”);

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws.

Table of contents:

• What Personal Information we collect, why we collect it and how it is used
• Legal basis for the processing of Personal Information
• Disclosure of Personal Information
• Transfers of Personal Information
• Your rights
• Links to other websites
• Analytic tools
• Data security
• Data retention
• Children's privacy
• Questions regarding our Privacy Policy
• Revisions and modifications to our Privacy Policy

WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED:

When you register or visit our Website:

• Personal Information you share directly with Medison:
  • We collect information from which you can be personally identified, including but not limited to your name, email address, telephone number, company, and any other information that you choose to share with us. Personal Information shall be collected only if received voluntarily from you, including, without limitation, by completing the Contact Us form or any other form available on the Website or by asking to join our mailing list.
  • Information that is shared when you, as an HCP (Health Care Professional), register for our professional platforms, such as name, license number, title, profession, expertise, address, working place, e-mail address, and telephone number, and professional photo.
  • We will collect your Personal Information to respond to your specific request and provide you with the information you wish to receive. Such a collection of information will enable us to provide you with technical and professional assistance.
  • If you subscribed to our mailing list, we will use your data in order to send you (to the email address you have provided upon your registration) newsletters and updates as well as to update you on events that we organize (as well as those that are organized with third parties). You may choose to unsubscribe from our mailing list at any time be clicking the "unsubscribe" link in the newsletter.

  We will process such Personal information to provide you with Our services, for example, registering and/or accessing our platforms; to communicate with you; access to our Website via various platforms you registered to; enable you to contact us; enable you to communicate with other members outside of the platforms, inter alia, via by the visibility of certain information about you - including your name, title, specialty, photo, and any professional details or content you choose to share with Us; to provide you with marketing information, including by direct marketing /advertising communications, and communication for market research purposes; receive professional updates and relevant news; share/present publications and insights within the platforms.

  We will process your Personal Information that you share directly with Us under our legitimate interest to provide you with the information you ask for and reply to your requests. We will also process it under our legitimate business interest to communicate with you. As an HCP registering on our various platforms, we will rely on your consent and our legitimate interest to deliver you the content on the Website which you have registered for.

  In certain cases, we may ask for your consent to process your data. This may include sending newsletters and other promotional communications to you or processing for registration for the Website. If and to the extent we rely on consent (whether implied or expressed) to process your data, you will have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

  You are not legally required to provide us with your Personal Data; however, if you choose not to do so, we may be unable, for example, to respond to your inquiries or enable you to access specific features on platforms.

• Other Personal Information that may be collected:
  • o We collect electronic data, such as your electronic identification data where required (e.g., login, access right, passwords IP address, logs, access and connection times, session durations, the content you accessed on the Website, the frequency and scope of your use of the Website and information about your computer and internet connection including the operating system you use and browser type. We also collect information about you through online identifiers/cookies and analytics tools (most of it is necessary and needed for functionality purposes). For more information, please read our cookie policy, available here.
  • o We will use such information to allow you to access the Website, manage and improve the functionality of our website, maintenance, security, and for analytical and statistical purposes under our legitimate interest. For more information, please go to our cookie policy, available here.

  Note that we may share this information with third-party platforms, such as email platforms and/or hosting providers, such as Google (as detailed below).

When we process for security and fraud prevention:

• Insofar as necessary, we may use your Personal Data to manage security and fraud, for example, to detect and prevent cyberattacks or attempts to commit identity theft, which is in our legitimate interests and it also serves your and third parties’ legitimate interests to keep our services and your Personal Data safe and secure.

When we process to protect our rights and to defend against lawsuits:

• We may use your Personal Data to protect our rights and to defend against lawsuits and to respond to legal and regulatory duties, such as requests from public and government authorities. We engage in these activities to comply with a legal obligation or because we have a legitimate interest.

DISCLOSURE OF PERSONAL INFORMATION:

In addition to the recipients described above, we may share your Personal Data as follows:

• With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies within Medison Group.
• To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
• If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
• In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
• Where you have provided your consent to us sharing or transferring your Personal Data (e.g., recruitment software).

TRANSFERS OF PERSONAL INFORMATION

• Your personal data may be processed or stored on servers or cloud providers located outside of the jurisdiction in which such information was originally collected, for example, we store some Personal Data with SPD Hosting with servers located in Israel. As a result, your Personal Data may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction.
  
  When transferring personal data outside of the jurisdiction in which such information was originally collected, we may share Personal Information with service providers, within our group of companies, or make disclosures to third parties (for example, to - United States, the UK, EEA, Switzerland, Brazil, Israel, Canada, etc.) where local privacy laws may vary. We implement appropriate measures to protect your Personal Information when we transfer it, such as, data transfer agreements that incorporate standard data protection clauses. In the event your personal data is transferred to persons in third countries that are located outside the European Economic Area ("EEA"), we will ensure that the personal data is subject to measures that provide an equivalent level of protection as provided by data privacy laws in the EU (such as the EU General Data Protection Regulation; GDPR), For example, when personal data is shared with other entities within the Medison Group, it may be transferred to countries that benefit from an adequacy decision by the European Commission under chapter V, and/or based on contractual arrangements that provide appropriate safeguards to ensure an adequate level of data protection.
• In jurisdictions where local data-storage or data-processing requirements apply, we will comply with the applicable legal obligations, including any requirement to store or process Personal Data locally. Any transfers of Personal Data outside the relevant jurisdiction will be carried out only in accordance with the law.
• We may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

YOUR RIGHTS:

You have the right at any time to request to access, modify your information, object to or restrict processing. To exercise these options, please contact us at privacy@medisonpharma.com.

In some jurisdictions, in particular those located within the European Union or within the European Economic Area, you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
2. Object to the processing of your Personal Information for direct marketing purposes.
3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
4. Object to an automated decision-making (including profiling) in certain circumstances.
5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
6. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.
7. Lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. If you wish to file a request regarding any of the above, you may contact us at: privacy@medisonpharma.com.

LINKS TO OTHER WEBSITES:

This Website may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by other providers of products or services, advertisers or other websites, companies or individuals, which are not owned or controlled by Medison. We suggest that when linking to another website, you always read that website’s privacy policy before volunteering any personally identifiable information.

ANALYTIC TOOLS:

• Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

DATA SECURITY:

We deploy industry standard, or better, measures to ensure the security, confidentiality, integrity and availability of personal data we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ‘need to know’ basis for the provision of services to you. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our site or to group companies, and transmission is at the users own risk.

DATA RETENTION:

Your Personal Data will be retained only for as long as necessary to fulfill the purposes for which it was collected as outlined in this Privacy Policy and until we delete or anonymized the record or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. Regarding retention of cookies, you can read more in our cookie policy.

CHILDREN'S PRIVACY:

The Website is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under age of majority. If you are under age of majority, do not provide any Personal Data to us without the involvement of a parent or a guardian. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@medisonpharma.com.

QUESTIONS REGARDING OUR PRIVACY POLICY:

If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at privacy@medisonpharma.com. The data controller of this Privacy Policy is Medison Pharma Ltd.

REVISIONS AND MODIFICATIONS TO OUR PRIVACY POLICY:

We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies.

Last updated in November 2025