This policy addresses the way we process and protect information. This policy does not apply to information that we process in connection with providing or receiving services under a contract. Our processing of such information is governed by such contracts and other relevant privacy notices. You might be provided with a privacy notice or policy provided to you for a specific purpose. If that is the case, the terms of such more specific policy, notice or contract will control your interaction with Clinago, powered by Innovaderm, to the extent that such policy, notice or contract conflicts with this policy.


“Information” is any information the we collected or process, including, but not limited to:

  • Information that identifies an individual, including personal, sensitive or health information.
  • Contact details.
  • Survey data.
  • Professional and/or educational credentials.
  • Transaction and/or financial information.
  • Communications.
  • Usage, online activity or device identifiers.
  • Any other information required by law or needed to achieve the purpose it was collected for.


Innovaderm will only collect, use and disclose your Personal Information with your consent, except where otherwise permitted or required by law.

You may withdraw your consent to our collection, use and disclosure of your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice.

The withdrawal of your consent does not affect the lawfulness of such processing that occurred before its withdrawal.

Limiting Collection

We only collect the Personal Information that you volunteered to us and your information will be used only for the purpose for which it is collected. You will always be informed when we need to collect your Personal Information and the reason why we need it.

You are not required to give us any of your Personal Information, but we will not be able to provide you with our services or address your requests without it.

Your Personal Information may be collected, upon your consent when you, among other instances:

  • Contact us to register in our recruiting database or complete a telephone questionnaire to participate in a research study.
  • Is seen in our clinic for a medical screening visit to assess eligibility for a research study.
  • Is seen in our clinic for a research study visit.
  • Participate in a study managed by Innovaderm.
  • Apply for a job with Innovaderm.
  • Ask for information on the services we provide.
  • Contract with Innovaderm for the provision of goods and/or services.
  • Any other instance where we need to collect Personal Information.

We do not knowingly collect Personal Information from minors, and we do not use any information upon discovering that it has been provided by a minor.

Innovaderm will not sell or make your Personal Information available to any third party.


Your Personal Information is kept confidential and secure and is not disclosed to any 3rd parties without your consent, unless required by law.

Innovaderm has a Confidentiality Officer who is responsible for ensuring that your personal information is collected, used, disclosed (shared) and retained in compliance with applicable privacy regulations.


You may access and verify the accuracy of your personal information upon written request. Once your identity is verified, we will respond to your request to access, update, or delete your Personal Information.

Your Personal Information is kept for as long as necessary to accomplish the purposes it was collected for. The period your information is kept may extend beyond the end of your relationship with us. Also, a longer retention period may be required for safety reasons or by law.

Job Application

Innovaderm uses a human resource tool (Comeet) to manage its recruiting process. If you are applying for a job via Innovaderm’s website, your Personal Information will be process and protected as per this policy.

For more information on how your Personal Data is processed by Comeet, please follow this link:

Note that in case of any conflict between the terms of Innovaderm’s privacy policy and Comeet’s, the terms of Innovaderm’s privacy policy will prevail.

Data retention

Personal Information will be retained: (i) for as long as necessary to accomplish the purpose it was collected for; (ii) for the timeframe you consented; (iii) until you withdraw your consent for our processing of Personal Information; or (iv) for the legally required period, as applicable.

Data transfer

Personal Information will be transferred to subcontractors working on Innovaderm’s behalf, as necessary to accomplish the purpose your Personal Information was collected for.

Should any international transfers be made, they will follow the applicable legislation in order to ensure your information is protected. This includes ensuring adequate safeguards, under GDPR (General Data Protection Regulation 2016/679) for Personal Information transferred outside of Europe.


Innovaderm has a procedure in place in order to receive and respond to complaints or inquiries about its policies and practices relating to the handling of Personal Information, as well as for the withdrawal of your consent or for the exercise of any right granted under an applicable law. Please contact us, at the address or email below:

Innovaderm Research Inc.
Attn: Privacy Officer
3530 boul. Saint-Laurent, Suite 300
Montreal, QC H2X 2V1


This policy may be amended or modified, from time to time, as permitted by applicable laws and regulations. Changes made to our privacy practices will apply to all the Personal Information that we hold.


Despite communicating with Innovaderm for any concerns or questions you may have about the processing of your Personal Information, you have the right to file a complaint with your local data protection authority.

We shall collaborate with any requests for information from such authorities, in order to resolve the issue as promptly as possible.

California Consumer Privacy Act of 2018 (CCPA)

When collecting or processing Personal Information from California residents, Innovaderm will comply with the terms of CCPA.

This section does not apply to individuals who provide Innovaderm with information as representatives of their business (whether sole proprietor or otherwise), who provide information in their business capacity.

  • Information. Consumers can request information about the Personal Information we collected about them and how we have used and shared their Personal Information during the past 12 months.
  • Access. Consumers can request a copy of the Personal Information that we have collected about them over the past 12 months. In certain cases, we are not permitted by the CCPA to provide you with certain sensitive information in response to an access request, such as your social security or driver’s license number.
  • Deletion.Subject to the exceptions listed in the CCPA, Consumers can ask us to delete the personal information that we have collected from them.

General Data Protection Regulation 2016/679 (GDPR)

  • If you live in Europe and we collect or process your Personal Information you have, among other rights, the right: (i) to access, update or delete your information; (ii) to obtain a copy of your information; (iii) to port you information in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller.
  • If you wish to exercise any of these rights, contact our Privacy Officer as indicated in Contact, hereto.
  • You also have the right to file a complaint with the relevant supervisory data protection authority, according to Article 77 of the GDPR, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR.

Data collected by automatic means

Several technologies can be used on our website to make them more user-friendly, efficient and reliable. These technologies may include an automatic data collection by ourselves or by third parties on our behalf. In general, these data do not contain personal details about the user. These technologies include, in particular, cookies, Adobe Flash cookies and analytics software.


A visit to one of our websites causes the browser to send data to our server. This data is automatically collected and stored by us or by others on our behalf. This data may include, in particular:

  • IP address of the visitor
  • the date and time of visit
  • the referral URL (the website from which the visitor came)
  • pages visited on our website
  • information on the browser used (type and browser version, operating system, etc.)


On our website, Cookies can be used in several places. In general, these small text files stored on the hard drive of your computer or your mobile device through your web browser. Cookies help to make our website more user-friendly, more efficient and more reliable. The cookies we commonly use are “session cookies” which are automatically deleted at the end of the visit of the web site. By default, browsers allow the use of cookies, but this feature can also be disabled. However, some services may not be available. It is also possible to manually delete cookies after use, using the Web browser. Innovaderm is not aware of cases where Cookies reportedly damaged a computer or mobile device or contributed to viral infection.

The following links provide detailed information on the most popular browsers:

Internet Explorer:

Mozilla Firefox:

Google Chrome:


Web Beacons and links trackers

Web beacons (also called “pixel tags” and “healthy GIF”) contain graphic symbols that the user cannot see. The links trackers or similar technology consist of a few lines of code instruction and can be incorporated into our website or our application (mobile). With Cookies, they are mostly used for statistical analysis. This technology can also be used to monitor traffic patterns on websites or to find out if an email has been received and opened, and if a response was given to it.


The term “cybermetrics” means a method of collecting and evaluating the behavior of Web site visitors or (mobile) applications. The latter includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a Web site or application (mobile) or to find out what information and services most interest our visitors. To do this, we essentially use clickstream data and other techniques described above. The cybermetric data are managed by Google Analytics. You can find more information on the treatment of data by Google Analytics cybermetrics developed below.

Cybermetric Data Processing By Google Analytics

The cybermetric services used on our website and our (mobile) applications are provided by Google Analytics ( This means that when you visit our website, a Google Analytics cookie is placed on your computer or mobile device unless the settings of your browser do not allow these Cookies (see 2.1.2 above).

Furthermore, when you visit our website, cybermetric data described previously in Chapter 1 – including “clickstream data,” the data provided by “web beacons and links trackers”, and the information stored in cookies Google Analytics – Google Analytics will be sent to be analyzed to Innovaderm.

Google Analytics operates as an agent of Innovaderm, which means only Innovaderm determines the purposes for which the data are used and that Google Analytics cannot disclose information to third parties (unless required to do so by law or by a court decision).

In terms of respect for private life, it means total Innovaderm is the “guarantor” and Google Analytics and the “data processing clerk.” You can find more information on the relationship between Innovaderm and Google Analytics in Google Analytics privacy policy to “Privacy Policy” at the following address:

If you do not want that information about your visits to our website is collected and evaluated by Google Analytics, you can refuse it. This means that Google Analytics make anonymous information it collects (but continue to collect), or stop collecting information about your visit, depending on the type of opposition you have chosen. This opposition forces you to accept that a cookie is placed on your computer by Google Analytics. You can ask to object by clicking on the link provided for this purpose in the part of the website that contains the Google Analytics privacy policy.


Retargeting technologies

Our website uses retargeting technologies on the Internet. Thus, visitors who are already interested in our services can view our advertisements on partner websites. We are confident that the display of personalized advertising, based on interest, is more interesting than publicity unrelated to the person.

We also work with other companies that use tracking technologies. These companies provide advertisements on our behalf across the Internet. It is possible that these companies collect non-personally identifiable information about your visits to our website and your interaction with our communications, including advertising.

Retargeting technologies analyze your Cookies and display advertisements based on your Internet behavior. For more information about cookies, please see section 1 of this Privacy Policy.

This technology does not ask for nor records any of your personal information. In addition, the use of our retargeting technology conforms to the current applicable requirements for the protection of privacy.

You can disable the use of cookies by Google by accessing Preferences Manager announcements. You can also disable the use of cookies by a third-party vendor to the Network Advertising Initiative opt-out page and DoubleClick deactivation page or off page Network Advertising Initiative.