SOCIAL MEDIA PUBLIC COMMENTS AND MENTIONS POLICY – THEA VERSION 07.2023

Purpose of the document

The social media public comments and mentions policy document is applicable to all social network accounts published by Théa Pharma Inc. (hereafter “Théa Pharma Canada”), including without limitation, any content published on Théa Pharma Canada’s YouTube channel, LinkedIn page & Instagram page. The purpose of these corporate accounts is to provide the audiences with contextual information on ophthalmology (information about pathologies, ophthalmic congresses, etc.) and news about Laboratoires Théa at corporate level and Théa Pharma Canada.

Acceptance

By joining and using Théa’s social media account, you agree that you have read and will follow the following rules that are stated on the social media public comments and mentions policy. Please take a moment to acquaint yourself with these important rules. Your use of, participation in, or engagement with our social media channels constitutes your acknowledgement and acceptance of this Policy.

Rules

While we give support to followers to share thoughts and opinions on Théa’s social media pages, we expect that this will be done in a respectful way. First, please understand that we work in a regulated industry and cannot engage in sensitive topics, such as discussions about products (ours or other pharmaceuticals companies’) or treatment options on the pages. These discussions are best held privately with your healthcare professional.

By browsing or sharing content on Théa's social network accounts, followers acknowledge that they have accepted the social media public comments and mentions policy and undertake to follow all the rules stated in this document. The policy is available on the social media page of Théa.

Be aware that the Théa social media public comments and mentions policy apply only to Théa social network accounts, and not to websites/social networks owned by third parties.

Théa Corporate accounts offer users the possibility to comment and make contributions. Be aware that Théa does not agree with or favour every comment that individuals post on our pages. Our target is to share ideas and information with as many individuals as possible and our policy is to accept most of the comments made to our profiles.

Therefore, a comment will be deleted if it contains:

  • Products with promotional mentions,
  • Health offers or medical advice,
  • Profanity, obscenity or vulgarity,
  • Nudity in profile pictures,
  • Defamation to a person or people,
  • Name calling and/or personal attacks,
  • Comments which main purpose are to sell a product, service, to recruit fans and followers,
  • Comments that infract on copyrights,
  • Spam comments, such as the same comment posted repeatedly on a profile, or any comment that is manifestly unlawful under any applicable laws and regulations and/or constitutes a criminal offence.

All links posted as comments on Théa posts will be reviewed and may be deleted. Repeated violations of the Théa comment policy may cause the writer to be blocked from the Théa’s social media profiles in the context of a retrospective review.

This retrospective review is carried out within 24 hours from the publication of the comments in accordance with applicable laws and regulations and Théa’s internal procedures, in particular the regulations relating to pharmacovigilance/quality, pharmaceutical regulations, regulations relating to the protection of personal information and personal health information, including without limitation the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and The Personal Health Information Protection Act, 2004 (Ontario) (“PHIPA”). This review is applicable to Théa’s social network accounts allowing comments/contributions and aims to ensure that these comments comply with the Théa comment policy and, more generally, with any applicable laws and regulations. In particular, it aims to ensure that no quotation and/or direct or indirect reference to a medicine is made in the comments.

Side Effects / Quality issues / Medical enquiry

If you trust that you have experienced any side effect or reactions regarding a Théa product, you should consult a healthcare professional immediately. You should also declare it to the pharmacovigilance service by visiting Théa Pharma (theapharma.ca) or directly emailing Quality.Canada@Theapharma.com. Posts regarding quality complaint and/or medical enquiry should also be declared using the same contact form.

Data Protection

We are not collecting any data from your LinkedIn, YouTube & Instagram profile (like email, ID or other personal details) except in the following cases:

  • In case of adverse event or product issue you report to us, the personal information collected in connection with your adverse event report is processed by Théa and its parent company Laboratoires Théa S.A.S., the controller, for the purpose of preventing, monitoring, evaluating and managing adverse health events related to our products.

The personal data we collect is limited to that which is strictly necessary for the assessment of the adverse health event:

  • Concerning the person exposed to the adverse event: date of birth, sex, weight, height, health data, other data necessary to assess the adverse event (e.g. risk factors such as smoking, alcohol or use of drugs);
  • Concerning the reporter: surname, first name, postal address, telephone numbers, email address, details of whether the reporter is a health professional and his/her specialty, whether the reporter is related to the patient, whether the reporter is a member of an approved association, whether the reporter is a member of a health authority, etc.

The reporter’s contact details are necessary to be able to contact him/her in order to obtain a satisfactory level of quality and complete information on the reported adverse health event.

The collection and processing of this data is necessary to comply with our pharmaceutical regulations and with PIPEDA and PHIPA. The recipient of this data is Théa Pharma Canada’s pharmacovigilance/regulatory services team.

Your personal data will be kept for the applicable legal period and will only be accessible to authorized personnel.

You have the right to request access, rectification and, in some cases, deletion of your data. For any request or to obtain more information about the processing of your personal data, please contact us by email at Privacy.Canada@theapharma.com or by mail at Théa Pharma Canada at 10 Four Seasons Place, Suite 802 Toronto, Ontario, Canada, M9B 6H7.

If you want to contact us in order to declare or obtain more information about any inquiries or medical side effects, please used the contact form Théa Pharma (theapharma.ca)., In doing so, we will also collect some personal data (name, location, health information etc.). The collection and processing of this data is necessary to comply with our pharmaceutical regulations and with PIPEDA and PHIPA. The recipient of this data is Théa Pharma Canada’s pharmacovigilance/quality/regulatory services team.

We understand that social media is a 24/7 medium, however, our review capabilities are not. We may not see every improper comment right away, and we are trusting in the wisdom of our community to avoid personal attacks and negative speech, and to behave politely.

Please contact Communication.Canada@theapharma.com if you have any questions.

Thank you for following Théa Pharma Canada on @TheaPharmaCanada on YouTube, LinkedIn & Instagram.