PRIVACY POLICY

(Last Updated: October 2011)

Janssen Inc. (“Janssen”, “we”, “us” or “our”) recognizes our responsibility to protect personal information in our custody or control. “Personal information” is information about an identifiable individual, such as your name, address, email address, phone number, health information, and comments or inquires you have made about our products or services when such comments or inquiries are linked to you.

This Privacy Policy applies to individuals we deal with in Canada including consumers, patients, health care professionals and others within the health care or pharmaceutical industries (“you” or “your”), and explains how we collect, use, disclose and protect your personal information. This Privacy Policy does not apply to information about our employees or to information that is not personal information.

Personal Information Collection

Janssen and its agents and representatives collect personal information in a number of circumstances, including when you provide it to us voluntarily or in other circumstances with your consent or as permitted or required by law. For example, we may collect your personal information when you:

• request information;
• inquire or provide comments about our products and services;
• participate in advisory boards;
• participate in clinical trials;
• participate in contests or other promotions;
• fill out questionnaires or surveys;
• participate in social media, or post information on bulletins or on our web sites;
• submit your resume or other personal information in connection with employment possibilities with us; or
• otherwise provide your personal information to us, including by telephone, mail, email, facsimile or through any of our web sites.

The information we may collect includes:

1. personal and business contact information, such as name, title, address, telephone number and email address;
2. information that our sales representatives may collect during their visits with physicians and other health care professionals with whom they deal, for instance title, qualifications, areas of practice or specialization, their questions or comments about our products, and related information about health care professionals and their administrators relevant to maintaining and managing our relationship with such persons;
3. names and other contact details of patients who use our products and their physicians and, in certain circumstances, sensitive health information, and patient medical history, for example, where we have received a report of an adverse event, where we are providing patient-specific assistance with respect to the use or reimbursement of our products, or where we are assisting in or co-coordinating product recalls;
4. information collected in connection with inquiries or comments made by individuals who contact our Medical Information representatives;
5. names and other contact details of physicians participating in advisory boards and the opinions or comments expressed by those physicians during advisory board meetings;
6. names and other contact details of physicians involved in running clinical trials, together with their professional information such as curriculum vitae and other information that is required to be reported to Health Canada and other regulatory bodies;
7. information such as name, age, and gender of patients participating in clinical trials together with the clinical data collected in the course of the clinical trials. Janssen generally receives patients' clinical data that has been recorded using identifiers other than the patients' full name, such as the patients' initials. More comprehensive patient data, including full names, may be reviewed by our clinical site managers when they attend at the trial site for compliance monitoring;
8. information from individuals visiting our premises such as their name and the name of the organization for which they work or which they represent. We may also post video cameras in public-access areas on our premises; and
9. other information with your consent or as permitted or required by law

Calls to and from Janssen may be recorded and/or monitored for quality and training purposes. Recordings may also be used to help us develop and improve our products and services. Information may also be actively and passively collected by our web sites. See Our Web Sites below for details.

Purposes

Janssen collects personal information for a variety of purposes relating to the operation of our business and the delivery of services to you, including to:

1. provide our products and services and generally manage and administer our business including maintaining business records for reasonable periods and defending and bringing legal actions;
2. develop and improve our products;
3. provide you with health and product-related information;
4. reply to your requests, inquiries and comments;
5. receive and assess product inquiries, reports of adverse events, and product complaints;
6. assist in or co-ordinate product recalls;
7. establish and maintain our relationship with health care professionals and administrators and other individuals with whom we have contact in the course of our business;
8. provide assistance and advice to health care professionals and institutions with respect to our products;
9. test and analyze our products for efficacy and safety;
10. meet legal, regulatory, insurance, security, ethical and processing requirements such as adverse event and clinical reporting to Health Canada and regulatory bodies;
11. monitor compliance with informed consent requirements when patients participate in clinical trials, and verify that clinical data collected by Janssen in the course of the clinical trial conforms to the source data available at the site of the clinical trial;
12. use feedback provided to us in the course of advisory board meetings to develop the strategic positioning of our products;
13. manage, administer, collect and enforce accounts;
14. provide remuneration to individuals who have performed services for Janssen;
15. enable us to act responsibly in the event of a health or other crisis or emergency and to enhance workplace security;
16. evaluate resumes or other personal information submitted to us in connection with employment possibilities. For candidates who are not offered or do not accept a position, we may retain their information in the event that an appropriate position becomes available or that they re-apply to Janssen;
17. offer and administer contests, promotions, surveys and web sites including social media;
18. ensure the security and integrity of our web sites and operations.

We may also use your personal information for other purposes with your consent or as permitted or required by law.

Use of Service Providers

We may transfer personal information to outside agents or service providers (including affiliates acting in this capacity) that perform services on our behalf, for example: certain payroll and benefits administration functions; receipt and administration of certain adverse event or product quality complaints; certain credit card, billing, mailing, marketing, information technology and/or data hosting or processing services, or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy. Some of these service providers may be located outside of Canada, including in the United States. While outside of Canada, your personal information will be subject to applicable foreign legal requirements, which may include lawful requirements to disclose personal information to government authorities in certain circumstances.

Disclosures

Janssen may disclose your personal information in the following circumstances:

We may disclose personal information when required in order to meet legal, regulatory, industry self-regulatory, insurance, audit, security or ethical requirements, including obligations to health and drug regulatory and self-regulatory bodies, physicians, hospitals, or other health care facilities.

Your personal information may be used by Janssen and disclosed to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of Janssen's business or assets, including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction or business relationship and to fulfil reporting or audit requirements. Assignees or successors of Janssen or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

We also may disclose your personal information to third parties, located in Canada and/or any other country, where required or permitted by applicable laws, court orders, or government regulations (including as required by Canadian and foreign laws applicable to Janssen or our agents and service providers).

We may also disclose your personal information with your consent.

Consent

Consent to the collection, use and disclosure of your personal information may be given in various ways. Consent can be express (express consent may be oral, in writing or electronic), implied (such as when you provide your name and address in order for us to send you products or information you have requested) and may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Generally, by providing us with your personal information, we will assume that you consent to our collection, use and disclosure of such information as described in this Privacy Policy, if applicable, or otherwise at the time of collection.

If you have provided us with personal information and wish to withdraw your consent to its retention, use or disclosure, please contact us as described below in the Access, Correction and Contacting Us section. You may withdraw your consent, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Policy or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, maintaining reasonable business records and disclosures to Canadian and foreign government entities where required by law).

There are instances where we may be permitted or required by law to collect, use or disclose your personal information without your consent including, for example, to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

Security

We may establish and maintain a file of your personal information for the purposes described in this Privacy Policy, which will be accessible at our offices. Authorized employees, agents and mandataries of Janssen who require access to your personal information in order to fulfill their job requirements will have access to your personal information.

We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information. Janssen will take appropriate steps to ensure that personal information about you is protected from loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

Although we have enacted security measures, we cannot guarantee the security of any information that you submit via email or over the Internet. Submission of personal information using such networks is done at your own risk, since no Internet transmission is ever 100% secure or error-free (in particular, emails sent to or from our web sites may not be secure). You should take special care in deciding what information you send to us via email or posting on our web sites. Moreover, where you use passwords, ID numbers or other special access features on our web sites, it is your responsibility to safeguard them. Our web sites may contain links or references to other web sites to which this Privacy Policy does not apply. Janssen is not responsible for the data collection and use practices of companies or organizations to which the Janssen web sites may provide links. We encourage you to read the privacy statement/policy of every web site you visit.

Access, Correction and Contacting Us

You may contact us as described below in order to:

1. receive a copy of the most current version of our Privacy Policy;
2. communicate any questions, comments, or concerns about our Privacy Policy or personal information handling practices or to request additional information;
3. request to withdraw your consent to our retention, use or disclosure of your personal information; and/or
4. request access to or correction of your personal information.

Requests regarding items 3 and 4 above must be made in writing. We will take reasonable steps to verify your identity before granting access or making corrections.

You may contact us by:

1. writing to us at the following address:
   Janssen Inc.
   Attention: Chief Privacy Officer
   19 Green Belt Drive
   Toronto, Ontario M3C 1L9
2. faxing us at 416-449-2658, attention Chief Privacy Officer, Janssen Inc.; or
3. emailing us at chiefprivacyofficer@its.jnj.com.

You may also view a current copy of our Privacy Policy at www.janssen.ca.

NOTE: If you are a physician or other health care professional and have questions or comments regarding our products, please contact our Medical Information Group at 1-800-567-3331.

Janssen’s Web Sites

Active Information Collection

Our web sites may actively collect information from visitors both by asking you specific questions and by permitting you to communicate directly with us via email and/or feedback forms. Some of the information that you submit on our web sites may be personal information.

Passive Information Collection

As you navigate through our web sites, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, web beacons and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the web site some of this anonymous information, such as the URL of the web site you just came from and the Internet Protocol address and the browser version your computer is currently using. Our web sites may also collect anonymous information from your computer through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of our web sites might not work without cookies.

Our web sites may use and combine such passively collected anonymous information to provide better service to site visitors, customize the sites based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the sites for your use. Such information is not combined with personal information actively collected on our web sites unless you have consented.

Cookies

The following is a description of cookies and other passive tracking methods.

A “cookie” is a bit of information that a web site sends to your web browser that helps the site remember information about you and your preferences.

“Session” cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate and collect aggregate statistical information on the site. They are erased once you exit your web browser or otherwise turn off your computer.

“Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the web site visitors find most valuable, and customizing the web site based on your preferences on an ongoing basis.

IP Addresses and Tags

A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider. In most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.

“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the web site server information such as the IP address and browser type related to the visitor’s computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted. “Navigational data” (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, for market research purposes, and to communicate information to visitors.

Privacy Policy Changes

This Privacy Policy may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this Privacy Policy, we will make reasonable efforts to notify affected individuals, if necessary, including by posting the revised Privacy Policy on this site. We recommend that you review this Privacy Policy frequently. Your continued provision of personal information or use of our web sites following any changes to this Privacy Policy constitutes your acceptance of any such changes.