Effective Date: January 17, 2018
- Personal Information
Personal information may include, for example, your name and home address, your date of birth and gender, health information, payment information, your occupation, medical conditions or other health information, your personal financial records or credit information, or any personal identification numbers.
- Consent for the collection, use and disclosure of PI
Privacy legislation requires us to obtain the consent of an individual to the collection, use or disclosure of PI in many circumstances.
When we receive PI or PHI from you for the purposes of providing you with our Platforms, products or services, and Pharmacy Services and Support Services, or for other uses identified herein, you are providing us with consent as follows:
- to allow us to deal with that PI and PHI in a reasonable manner;
- to allow us to provide your PI and PHI to third parties we engage to provide or support the Platforms;
- to allow us to use and store your PI and PHI for the purpose of providing you with the products and services you purchase from us and to utilize the Platform, Pharmacy Services and Support Services; and
- to allow us to transfer your PI outside of Canada (whereby your PI will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your PI by us.
If you need to provide us with PI or PHI about other individuals, you represent and warrant to us that, where required by law and prior to your disclosure to us, you will obtain the consent of each individual to the collection, use and disclosure by us for the specific purpose(s) that the disclosure is made by you.
Providing us with your PI and PHI is always your choice. When you request products and/or services from us, or utilize us to access Pharmacy Services or Support Services, we ask that you provide information that enables us to respond to your request and/or provide you with our services. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such PI and PHI for these purposes.
- Consent Exceptions
There are legal exceptions where we will not need to obtain consent or explain the purposes for the collection, use or disclosure of PI. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if we must comply with a court order or governmental order.
We may use PI without your knowledge or consent in limited circumstances whereby we are required to provide PI to third parties for legal or regulatory purposes. For example, under certain exceptional circumstance we may have a legal duty or right to disclose PI without your knowledge or consent. Various government agencies such as the Canada Revenue Agency, Human Rights Commission, Canadian Radio-television and Telecommunications Commission, and law enforcement, may have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.
- What PI and PHI do we collect and use?
Generally, you may browse our Websites or the Apps without providing any PI. You are under no obligation to provide us with PI, with the caveat that your refusal to do so may prevent you from using certain portions of the Websites or the Apps.
As set out above, HCPs and PCAs are responsible for the collection, use and disclosure of PI and PHI as it relates to the provision of Pharmacy Services and Support Services and for ensuring that adequate safeguards are in place to protect that information. The following overview provides general information about how PHI or PI is collected and used through the Platforms.
In order to use the Platforms and to receive Pharmacy Services and Support Services you may be required to create a user account (the “User Account”) through the Platforms and be issued a username and password login credentials (“User ID”). We collect information such as your name, email address, phone number, gender, date of birth and province or territory to create your User Account. If you are issued a User ID, you will be required to keep your User ID secure.
The Pharmacy Services and Support Services are also available for use by children at the discretion of the HCP or PHA. For all patients under the age of 18, the holder of the User Account and User ID, must be the patient’s parent or legal guardian. You may be asked to provide PI or PHI about your child in order to register them to use your User Account (“Registered Child”).
Provision of Pharmacy Services and Support Services
We collect PI or PHI on behalf of the HCP or PHA when you request Pharmacy Services or Support Services to facilitate the provision of those services and to assist you in connecting with the HCP of your choice.
We collect your provincial health card number in order to bill provincial health plans for those services that are eligible for coverage by provincial health plans on behalf of the HCP and/or your financial information to facilitate payments in respect of your use of the Platforms or the receipt of any services through the Platforms.
We may further collect your health insurance information in order to bill such health insurance plan for those services or pharmaceutical products that are eligible for coverage by such plans on behalf of the HCP.
HCPs and PHAs collect and use PI and PHI about you or a Registered Child in order to provide you or your child with Pharmacy Services and/or Support Services. HCPs and PHAs may collect PHI about you verbally or by text, including the reason for your consultation request; relevant health history and present condition or symptoms. The HCP may access PHI that you have entered or up