PRIVACY POLICY
Unless expressly stated otherwise, terms defined in our Terms of Use and used in this Policy have the same meanings as in our Terms of Use.
This Policy applies to Personal Information collected by PharmaGap, including whether you are a Professional or a Client or a representative. This Policy applies whenever you interact with us, including when you access the Application.
Definition of “Personal Information”
“Personal Information” means any information that directly or indirectly identifies an individual (collectively, “individual” or “you”) or could reasonably be associated with that individual. Examples include your name, contact information, email address, and account information with us (as applicable). It should be noted that information concerning an individual’s performance of a function within a company, such as his or her name and position, as well as the address, email address and telephone number of his or her place of work, are not considered to be Personal Information.
What Personal Information do we collect?
The Personal Information we collect may include:
- Identifiers and contact information, such as your name, email and mailing addresses, telephone number, IP address (if it can be used to identify you), device identifier or account information (for example, if you created an account when you registered for the Services Offered) or your license number related to your professional activities.
- Browsing activities within the scope of the Services Offered, such as pages and offers viewed, opt-out preferences, email returns, clicks, social media content, and IP addresses, if this information identifies you as an individual.
- Geolocation information may be collected when you use the Services Offered, although this information does not always identify you as an individual.
- Messages, activities, and other information shared in the chat feature of the Application
- Any other information you provide to us that identifies you.
How do we collect Personal Information?
We collect Personal Information in a variety of ways, including directly from you, from technologies used at our establishment, through online technologies (for example, when you interact with us through the Application), from third-party social networks, and from other third parties. PharmaGap also encourages you to review the privacy policies of third parties. The third parties involved may use tracking methods such as, but not limited to, cookies, to fulfill their own business purposes by linking and combining information about your use of the Application with any other Personal Information they may have collected about you.
Specifically, we collect Personal Information in the following ways:
Directly from you
We may collect Personal Information directly from you, through the Application, when you create an account to access the Application or when you use the Application, by mail, email, telephone or otherwise directly in connection with the Services Offered, for example, when you make a request to our customer service department.
Through our service providers
From time to time, we may receive Personal Information from our service providers. We may also receive Personal Information from other sources with your consent or where permitted by law.
Through online technologies
With your consent or where permitted by law, we may collect certain types of information electronically when you interact with the Application. This information helps us improve our Application, understand your actions while using it, and allows the Application to function properly.
To learn more about your privacy policy choices, please see How can you change your privacy choices? below.
The technologies we use include:
- Cookies, are small text files that are stored on your computer when you visit a website so that information, such as your login credentials or language preferences, can be saved between visits. For example, cookies allow you to quickly log in to the Platform.
- Web analytics tools such as Google Analytics, which uses cookies to analyze your use of the Application, to create reports on user and visitor activities, and to provide other services associated with the use of our Platform.
- Analytics engines, which pull usage data from multiple sources and help manage and collect that data for use for personalization, interest-based advertising, content personalization and other methods to better understand our customers’ needs and preferences.
You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features related to the Services Offered. To learn more about your privacy choices, please see How can you change your privacy choices? below.
Third-Party Social Networks
We may collect your Personal Information if you interact with us through our social media pages and accounts (e.g., Facebook, Twitter, Instagram). For example, we collect the Personal Information that these social media platforms allow us to collect from our followers. We may also collect any content you upload to our social media pages and accounts (including photos or videos).
We may obtain and use analytical and statistical information from third-party social networks to help us measure the performance and effectiveness of the content we post on social media, for example, by measuring impressions and clicks on content.
From other third parties
In some cases, we may collect Personal Information from other categories of third parties, but only with your consent or as permitted or required by applicable law.
How do we use Personal Information?
We limit the collection of Personal Information to what is reasonably necessary to fulfill the purposes for which it was collected. We may use all the categories of information detailed in the section What Personal Information Do We Collect? to provide you with our products and services, to manage our business activities, to communicate with you offers and information that we believe may be of interest to you, to improve your customer experience with us, and as permitted or required by law.
We use your Personal Information for the following purposes:
Providing our products and services
- We use your Personal Information to provide our services, such as:
process your requests for reliefs services (also known as “replacements”) and confirm acceptance of relief contracts; - verify your identity;
- answer your questions;
respond to your requests or take or verify your instructions; - create, administer and maintain your accounts; and
- manage payments related to the services and use of the Platform in accordance with the Terms of Use.
Manage our business activities
We use your Personal Information to manage our business activities, for example to:
notify you of changes to your account or our Platform’s services, terms, or policies and provide you with administrative messages, updates, legal notices, technical notices, or security alerts;
deploy and manage our Platform and IT systems;
manage and facilitate the use of our Platform, which may include the use of cookies and other similar technologies;
protect ourselves and third parties from error and fraud;
monitor compliance with and comply with the Terms of Use,
investigate incidents and manage complaints;
Maintain our programs, products and services; and
comply with our contractual, legal and regulatory obligations.
Marketing and Advertising
We use your Personal Information to market our services by delivering online or email advertising that is relevant and personalized to you, including on social media platforms.
If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe instructions provided in each commercial electronic message. For more details on managing your advertising preferences, see Section 7 below, entitled: How can you change your privacy choices?
Conduct market research and data analysis
We may use your Personal Information to conduct market research and data analysis by tracking and analyzing your information for the following purposes:
improve or develop new products, services and programs, and better understand our customers and their behaviour;
manage and develop our business and operations;
improve our programs, products, and services (e.g., improve the Application); and
understand how users interact with the Services Offered, including the Application and ensure that they function properly.
To the extent possible, we will use your information in an aggregated and/or de-identified form.
How do we share Personal Information?
We may share your Personal Information within PharmaGap and with our service providers and certain third parties for the purposes described in this Policy and in accordance with applicable law. We will not share your Personal Information with unaffiliated third parties without your prior consent, except as provided in this Policy or as permitted by applicable law.
Within PharmaGap
PharmaGap may share Personal Information internally with certain employees where such sharing is necessary in the course of their duties and use it for the purposes described in this Policy.
Professionals, Clients and representatives
We may share some of your Personal Information with Professionals, Clients and their representatives only to the extent necessary to provide the Services Offered and for any other purposes set out in this Policy.
Service Providers
While providing the Services Offered, we may share certain Personal Information with third-party service providers who provide services to us. These service providers help us operate our business, technology systems and applications, internal procedures, and infrastructure. We may also share certain Personal Information, such as name, email address, and other contact information, with certain service providers, who provide services to us, such as processing contracts, sending email and postal mail, hosting data, providing advertising, and analytics services (e.g., tracking the effectiveness of our marketing campaigns and analyzing the use of our websites and applications).
Sale or transfer of the business or other transaction
We may disclose Personal Information to a third party in connection with a sale or transfer of the business or assets or stock, merger, reorganization, or financing of portions of our business (including insolvency or bankruptcy proceedings). If the transaction is completed, your Personal Information will remain protected by applicable privacy laws. If the transaction is not completed, we will instruct the other party not to use or disclose your Personal Information in any manner and to delete such information altogether, in accordance with applicable laws.
Other Permitted Grounds
Applicable laws may permit or require the use, sharing, or disclosure of Personal Information without consent in specified circumstances, such as to investigate suspected or actual illegal activities, to prevent such activities, including fraud, or to assist government and law enforcement agencies. These circumstances include those where it is permitted or required by law or where it is necessary to protect our group of companies, employees, customers or others. In such circumstances, we will only share Personal Information that is reasonably necessary to fulfill the purposes for which it was disclosed.
With your consent
In addition to the purposes listed above, we may, with your implied or express consent, share or disclose your Personal Information outside of PharmaGap, in accordance with applicable laws.
How do we manage consent?
By accessing or using the Services Offered, including through the Application, you submit information to us, you give your consent to the collection, use and disclosure of Personal Information, as provided for in this Policy. In some cases, your consent may be “implied,” meaning that your permission is deemed to be given based on your action or inaction at the time of collection, use, or sharing of your Personal Information.
We generally obtain consent when we want to use Personal Information for a new purpose or a purpose other than those set out at the time of collection in this Policy or in the terms and conditions of a specific product or service in which you have registered, participated in or purchased. You may have the right to withdraw your consent under applicable law (except in limited circumstances, including legal or regulatory requirements or because of your contractual obligations with us). For information on how to manage your privacy preferences, please see How can you change your privacy choices? below.
If you choose not to provide us with certain Personal Information or if you withdraw your consent, where such withdrawal is possible, we may not be able to provide you with the products, services or information that you have requested or that may be available to you, including the Services Offered.
How can you change your privacy choices?
We want you to clearly understand your choices and make informed decisions about your privacy options. You have several options for managing your privacy preferences, including:
managing your preferences in your account, if applicable,
contacting us directly or changing your browser settings on your device, or
using the unsubscribe feature that may be offered by a third party.
In your account
If you have an account with us, you can update your preferences in your account in the Application.
When you register or contact us directly
You may choose to receive marketing communications by email at the time you register for our programs, products or services, or at any time thereafter through your online account(s) and in connection with the Services Offered, including the Application, we may also have your implied consent to send you commercial electronic communications under applicable laws.
You may opt out of receiving marketing communications by email, by clicking “unsubscribe” in any commercial email you receive, by following the unsubscribe instructions provided when you receive a marketing email, or, in some cases, through your online account (if you have created one).
You may also withdraw your consent to other forms of marketing and advertising or to the use of your Personal Information for market research and data analysis purposes by contacting the Privacy Officer as set out in the section Who do I contact if I have questions about the protection of my Personal Information? Please note the following regarding withdrawing consent or changing your privacy preferences:
Although you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes, in compliance with applicable laws (e.g., for customer service, product or service information, etc.). We may also need to contact you with questions or information regarding your customer service requests; and
There may be a delay before all our records reflect changes to your preferences, for example, if you request not to receive personalized marketing communications from PharmaGap, your preference may not be considered for a promotion that is already underway.
Use of the Third-Party Unsubscribe Feature
With your consent or where permitted by law, we may use third parties (e.g., web companies or social media platforms) who use certain technologies to analyze your browsing behavior when you use the Services Offered. You can manage your privacy preferences in relation to certain third parties, such as Google, by using the unsubscribe feature on their platforms. Please note that disabling, blocking, or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features of our websites and applications.
For example, Google Analytics uses cookies to analyze your browsing behavior on our websites. This information is not provided to us in a format that personally identifies you and is collected through your advertising settings on your device or browser. If you want to opt out of Google’s ad settings, please go to https://adssettings.google.com/anonymous?hl=en or use the Google opt-out add-on located on https://tools.google.com/dlpage/gaoptout.
For more information about interest-based advertising or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Your web browser or device may also include features or settings that allow you to opt-out of the collection of certain information through applications used for behavioral advertising purposes; For more information, see your browser or device settings.
We may also embed links to other websites, including social media platforms, on our websites and the Application. For more information about social app plug-ins, such as “Likes” on X (formerly Twitter), Facebook or Instagram and their impact on your right to privacy, please visit the appropriate social media help center (e.g., the Facebook help center at https://www.facebook.com/help/).
How do we protect Personal Information?
We use administrative, physical, contractual and technical measures to protect the confidentiality of Personal Information and to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, considering, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguard measures also apply when we dispose of or destroy your Personal Information. We use reasonable safeguard measures to ensure that our service providers protect your Personal Information, regardless of where it is used or stored.
Additionally, we implement internal policies and practices that protect your Personal Information, including:
Designation of a Privacy Officer responsible for ensuring compliance with applicable privacy laws.
Policies and procedures that define the roles and responsibilities of our employees throughout the life cycle of Personal Information, limit access to that information on a “need-to-know” basis and govern the retention and destruction of Personal Information.
Contractual protections and other measures to ensure that service providers with whom we share Personal Information maintain adequate safeguard measures and security standards.
Our goal is to prevent unauthorized access, loss, misuse, sharing or alteration of Personal Information in our unauthorized possession. We also use these safeguards when we delete or destroy your Personal Information.
Where We Store Personal Information and Cross-Border Transfers
We may share Personal Information with certain service providers who may be located outside of your country or province or territory of residence. These service providers may also access, process, or store your Personal Information outside of the country and province where we are located and where you reside.
As a result, when your Personal Information is used or maintained outside of the province or territory in which you reside, it may be subject to the foreign law applicable in the jurisdiction where it is stored, including any laws permitting or requiring disclosure of the information to the government, government agencies, courts, and law enforcement authorities in that jurisdiction.
We will retain your Personal Information in accordance with our retention policies or as required or permitted or required by law. Once it is no longer needed, your Personal Information will be securely destroyed or anonymized (so that the information no longer identifies you, either directly or indirectly, under any circumstances).
What are your privacy rights?
The rights described above can be exercised in accordance with the requirements and restrictions set out by law:
- Your right of access: You have the right to ask us whether we use or retain your Personal Information. You may also request copies of this Personal Information.
- Your right to rectification: You have the right to request that we correct Personal Information that you consider to be inaccurate or ambiguous, and to complete Personal Information that you consider to be incomplete. You may also have the right to request rectification of your Personal Information if the collection, disclosure or retention of such information is not permitted by law. This correction can also be made by you by accessing your PharmaGap Account.
- Right to account deletion and personal data erasure: you can request the permanent deletion of your account and erasure of your personal data. To do so, go to the “General” section in your profile on the web or mobile apps., and click on “Delete My Account”. Once you confirm, your account and personal data will be permanently deleted. If you login using your Facebook account, you will need to perform the following steps to remove access to your Facebook data.
- Go to your Facebook Account’s Settings & Privacy. Click “Settings”.
- Look for “Apps and websites”, where you will see all the apps and websites linked to your Facebook account.
- Scroll until you find the “PharmaGap” app in the list of applications.
- Click “Remove”.
- At that point, your app activities are successfully removed from Facebook.
You can also request the deletion of your account from the PharmaPlan App simply by emailing us at cs@pharmagap.com
To exercise your rights, please contact our Privacy Officer at the contact information provided in section 12 below, entitled: Who do I contact if I have questions about the protection of my Personal Information?.
Changes to our Policy
We may make changes to this Policy from time to time. Any changes made will be effective when we post an amended version of the Policy on the Application and on PharmaGap’s website. If the changes we make are material, we will highlight them when required by applicable laws. By continuing to use the Services Offered after the posting of the modified version of the Policy or after you have been notified of such update, you agree to the changes to the Policy. If you do not agree to the changes to our Policy, it is your responsibility to stop using the Services Offered. It is your duty to ensure that you have read, understood and agreed to the latest version of the Policy. The “Effective Date” at the top of this Policy indicates when it was last updated.
Who do I contact if I have questions about the protection of my Personal Information?
If you have any questions about how we handle your Personal Information, concerns, requests, or would like to make a complaint, please contact us using the contact information below:
Privacy Officer
Mr. Michel Kassar
Phone: 514-331-5200
Email: mkassar@pharmaplan.ca