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Privacy

Rexall Pharmacy Group Ltd.

REXALL PHARMACY GROUP LTD PRIVACY STATEMENT

LAST UPDATE: August 12, 2016

Rexall Pharmacy Group Ltd. (“Rexall”) and its banner pharmacies, including Pharma Plus, Rexall™ and Rexall™ Pharma Plus respect the privacy rights of our customers and employees and are committed to protecting the personal information that we collect from you. We have adopted this Privacy Statement to guide how we collect, use and disclose the information you provide to us. Specifically, this Privacy Statement has been developed so that you can learn more about the policies and practices that we have developed to safeguard personal information, and to better understand our relationships with the third parties who may have access to this information.

This Privacy Statement applies to the collection, use and disclosure of personal information in the course of all commercial dealings with Rexall, including pharmacy and retail services and applies to the use of any website or mobile application maintained by Rexall, affiliates of which are operators of retail pharmacies in Canada. Websites include the Rexall.ca website,the MediTrust.ca website and Rexall Pharma Plus MyRexall Account Website (the “Sites”), and the Rexall Pharma Plus Mobile Application, and the Rexall Pharma Plus MyRexall Account Software Application for Mobile Devices (the “Applications”), and any other websites and applications that may be developed in the future.

For the purpose of this Privacy Statement, unless stated otherwise, all references to “Rexall” or “we” include Rexall Pharmacy Group Ltd.., as well as its affiliates and subsidiaries that are operators of retail pharmacies in Canada (and that provide pharmacy services to the MediTrust home delivery program).

Personal Information

Personal information is information about an identifiable individual, for example, their name, date of birth and email address. Personal information also encompasses personal health information, such as your medical records and other information about your health and your prescriptions, that has been collected or generated by your pharmacist.

Consent

You agree that we may collect, use and disclose your personal information in accordance with this Privacy Statement.

Rexall will collect, use and disclose personal information without your consent only in limited circumstances as permitted by law. There have always been, and may continue to be, instances where we may collect, use and disclose your personal information without your consent. These instances are permitted under privacy legislation in order to ensure that the consent requirement is not a hindrance to your health and safety. For example:

- personal information may be collected without consent where the collection is clearly in the interest of the individual and consent cannot be obtained in a timely way;

- personal information may be used without consent where it is used for the purpose of acting in respect to an emergency that threatens the life, health or security of an individual; and

- personal information may be disclosed without consent where the disclosure is made to a person who needs the information because of an emergency that threatens the life, health or security of an individual.

Other than described directly above, we will not collect, use or disclose your personal information for new purposes, unrelated to the purposes described in this Privacy Statement, without first obtaining your prior consent.

If you choose to later withdraw your consent to allow us to collect your personal information, we will still be obliged to comply with all the provincial laws that require us to keep records relating to the medication that we dispense to you. If you chose to not give us consent to disclose certain personal information, we may not be able to provide you with the full range of pharmacy services. For example, if you indicate to the pharmacy staff that you do not consent to communications with your insurance company, you may be required to pay for your prescription and send the information required for reimbursement directly to your pharmacy benefits plan.

Information We Collect

Rexall collects personal information for various purposes, including to:

  • provide healthcare related services;
  • process payments;
  • communicate with individuals involved in your care or the payment of your care;
  • provide health-related education communications;
  • communicate products and services;
  • provide loyalty programs, contests, promotions and other non-pharmacy related activities; and
  • manage the business

Rexall will inform you, when requested, as to why we must collect any of your personal information before the information is collected.

(i) Information We Collect In Pharmacies

When you first visit one of our banner pharmacies, your personal information will be collected in order to establish your record. Types of information we collect include (but is not limited to), prescription information (e.g. patient, medication and prescriber information), health information (e.g. allergies and medical conditions) and insurance information. Upon request, the pharmacist or one of their pharmacy staff will provide you with information on why your personal information is required and to whom they must disclose it in order to provide you with pharmacy services.
There may be times when you want us to share prescription-related information with a family member or authorized representative or, alternatively, to specifically restrict with whom we may share the information. We will comply with your request upon notification by you. For example, if you would like to have special provisions made for the pick-up or delivery of your prescription, we will follow your instructions upon your request. We will maintain a record of your instructions. Simply contact your pharmacy and they will be pleased to update this information.

(ii) Information We Collect Online

With respect to the Sites and Applications, in addition to the personal information that you provide to us with your account registration and the personal information that has already been collected by your pharmacist, we have access to the following categories of information regarding you and your visit to the Sites. Only some of these categories of information identify you directly, but each category offers some information about your interests and activities that could be used to make inferences about you.

IP Address. We record the Internet Protocol (IP) address of your computer when you visit the Sites. The IP address does not identify you personally, but it allows us to maintain communications with you as you move about the Sites.

Cookies. We also collect information about your use of the Sites through cookies and similar technology. A "cookie" is a unique numeric code that we transfer to your computer so that we can keep track of your interests and preferences and recognize you as a return visitor to the Site. Cookie technology allows us to collect "clickstream" data, which is not personally identifying information, but which reflects your activities on the Site, including your interest in certain healthcare conditions. A cookie does not collect or keep your name or other personal identifying information, but when you revisit the Site the cookie allows us to bring you the content and features likely to be of greatest interest to you based on your previous activities on the Site.

In addition to the personal information collected on the Sites regarding you and your visit to the particular Site, we may collect and use the geo-location information from your use of the Sites or Applications. This means that when you use the Applications, we may use GPS or similar technology to determine your current location. Your geo-location services can be turned off for the Applications either in your mobile device settings and/or within the Applications.

We will limit the collection of your personal information to that which is required to accomplish the purposes for which it is being collected. For example, if the purpose of the collection is to enable a pharmacy to submit a drug benefit claim to an adjudicator or benefit manager for payment, the pharmacy will only collect from you the information required to submit the claim.

Additional information regarding certain types of information collected online can be found below

Access to Your Personal Information

You have the right to access, update, and correct your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request to access, update and correct inaccuracies in your personal information that we have in our custody or control by contacting us at Toll-free: 1-877-378-4100 or sending an email to privacyofficer@rexall.ca. We may request certain personal information for the purposes of verifying the identity of any individual seeking access to their records.

To find out what information your pharmacist has about you, contact them in person or in writing. In most instances, they will respond to your request within 30 days. If you have any concerns about the access provided to you, or if you wish to amend the information, you are encouraged to discuss it with your pharmacist, who will be pleased to assist you.

Through the Sites and the Applications, you will be able to access your personal information that has been collected and generated by your pharmacist. In order for you to access your personal information through the Sites or the Applications, it must be shared between your pharmacist and Rexall.

By using the Sites or the Applications, your personal information will be disclosed by your pharmacist to Rexall, and Rexall will collect, use and disclose of your personal information in order to maintain and provide you with access to your personal information through the Sites and/or Applications.

How We Use and When We Disclose Your Information

Rexall uses personal information for a number of purposes, including as described below:

Treatment: We may use your personal information to provide you with pharmacy or health-related services. We may use your information to co-ordinate care with other pharmacies and health care providers as we have always done in the past. Examples include filling your prescription or speaking to your doctor regarding your prescription for clarification purposes. In order to provide you with quality health care and in compliance with existing federal and provincial legislation, we keep a record of the medications dispensed to you at our pharmacy. We also include in our records any relevant health information that we require to ensure that you are not given, or advised to take, a medication that is not appropriate for you.

Payment: We may use and disclose your personal information in order to receive payment for the drugs you receive. For example, we need to give information about prescriptions we have filled for you to your health plan, to obtain payment.

Communication with individuals involved in your care or payment for your care: Health professionals such as pharmacists, using their professional judgment, may disclose to your health care designate any personal information that is directly relevant to your designate's involvement in your care or payment for your care.

Health-related educational communications: We may contact you to provide refill reminders such as our e-Fill e-mail reminders or information about treatment alternatives, events in our stores, or other health-related benefits and services that may be of interest to you. We may also contact you about store openings or closings in your area.

Communication about products and services: We may use and disclose your personal information to tell you about or recommend possible treatment options or alternatives, or to tell you about health-related benefits or services that may be of interest to you.

Non-pharmacy Services and Products: We may collect your personal information in relation to non-pharmacy related services and products, including loyalty programs, contests, promotions.

Law Enforcement: In certain limited circumstances, we may be called upon to release your personal information in response to a court order, subpoena, search warrant, law, or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our Terms of Use, or other rules or engage in behavior that is illegal or harmful to other users of the Sites/Application.

Product Reports: If you contact us regarding your experience in using one of our products, we may use the information you provide in submitting reports to Health Canada, and as otherwise required of us by law. We also may use the information to contact your pharmacist or prescribing physician to follow up regarding an unexpected event involving use of a product purchased at a Rexall, Pharma Plus or Rexall Pharma Plus pharmacy.

Online Pharmacy Services: Rexall offers a number of online pharmacy services. We have outlined some of these services in greater detail, to describe how your personal information is collected, used and disclosed in these contexts:

(i) Online Prescription Refill

The Online Prescription Refill service allows you to request a refill of a prescription from the same Rexall, Pharma Plus or Rexall Pharma Plus pharmacy from which it was originally dispensed and where refills remain (or where, in some provinces, a pharmacist is permitted to authorize refills) and may be refilled by law. The use of the Online Refill tool requires the collection, use, disclosure and transmission of personal information across computer systems and networks. In light of the inherent nature of the Internet, we cannot guarantee that this information: (i) will be transmitted securely; (ii) will be error- or defect-free; or (iii) will not be improperly accessed or used by third parties. You are submitting this information over the Internet to us at your own risk.

Your request for a prescription refill will be transmitted to the pharmacy location you have indicated. Once the pharmacy has received the request, it will be handled in the same manner as all refill requests, at all times being subject to the dispensing pharmacist's professional judgment and ethical responsibilities.

By submitting the prescription information (and other required information), our representatives (including a pharmacist or a pharmacy technician or assistant) will have access to your personal information.

In order to properly dispense a prescription and for your health and safety, the pharmacy may have to contact (without limitation):

  • the prescribing professional to discuss the refill request and your medication history and medical conditions;
  • your health insurance provider in order to properly process your benefits (if applicable); and/or
  • such other persons or entities as may be required in order to properly process your prescription refill request.

In the course of such discussions, your personal information may be disclosed to the persons noted above.

(ii) Online Prescription Transfer Requests

The Online Prescription Transfer service allows you to transfer your prescriptions from another pharmacy to a Rexall, Pharma Plus or Rexall Pharma Plus pharmacy, or between Rexall/Pharma Plus/Rexall Pharma Plus pharmacies. The use of this service requires the collection, use, disclosure and transmission of personal information across computer systems and networks. In light of the inherent nature of the Internet, we cannot guarantee that this information: (i) will be transmitted securely; (ii) will be error- or defect-free; or (iii) will not be improperly accessed or used by third parties. You are submitting this information over the Internet to us at your own risk.

Your request for a prescription transfer will be transmitted to the pharmacy location you have indicated in your request. Once the pharmacy has received your prescription, it will be handled in the same manner as all prescriptions, at all times being subject to the dispensing pharmacist's professional judgment and ethical responsibilities. By using this service, our representatives (including a pharmacist or a pharmacy technician or assistant) will have access to your personal information.

In order to properly transfer and/or dispense a prescription and for your health and safety, the pharmacy that you have transferred your prescription to may have to contact (without limitation):

  • the prescribing professional to discuss the transfer request and your medication history and medical conditions;
  • your health insurance provider in order to properly process your benefits (if applicable); and/or
  • such other persons or entities as may be required in order to properly process your prescription transfer request.

In the course of such discussions, your personal information may be disclosed to the persons noted above.

(iii) Rexall Blood Pressure Tracker, powered by PharmaSmart (“BP Tracker Program”)

Through the Sites and Applications, you can access the BP Tracker Program, which will allow you to record, track and access your blood pressure measurements and other personal information (for example your glucose and cholesterol levels and your weight/BMI).To access the BP Tracker Program, you will need to register your Blood Pressure Check Card (“Card”) on the Sites and Applications by entering the Unique Access Code (“UAC”) found on the Card, along with other personal information.

You can also record your blood pressure measurements at certain Rexall, Pharma Plus, Rexall Pharma Plus pharmacies with your Card, using the PharmaSmart Blood Pressure Kiosks (“Kiosks”). The Kiosks are owned and operated by Pharma-Smart International Inc. (“PharmaSmart”).

The blood pressure data and results obtained from the Kiosks are processed and maintained in a database managed by PharmaSmart. Further, any information, including personal information, that you record in the BP Tracker Program through the Sites and Applications is also processed and maintained by PharmaSmart, in order to provide you with these services on behalf of Rexall. More information regarding Rexall’s relationship to third parties service providers, such as PharmaSmart, is contained below.

The personal information obtained through your use of the Kiosks or through the BP Tracker Program portion of the Sites and Applications will be accessible by all pharmacists practicing at the pharmacy where the Card has been registered, and will be shared with Rexall, PharmaSmart, and other third party service providers that manage the Sites and Applications and perform services in relation to the BP Tracker Program on behalf of Rexall.

Once enrolled, your personal information relating to the BP Tracker Program will be accessible to a pharmacist any time he/she accesses your patient profile. Should your blood pressure readings fall outside the target range, the pharmacist will be alerted to this fact when he/she views your patient profile at the time you receive prescription services. Based on this information, your pharmacist may provide you with certain patient services and information, including providing a consultation and information on hypertension/hypotension, as applicable.

Your pharmacist may also follow-up with your health care practitioner. In the course of such discussions, your personal information may be disclosed.

If you choose to subscribe to email/text message reminders or notifications relating to the BP Tracker Program, these communications may be sent to you by PharmaSmart or by one of our other third party service providers.

Sites and Applications: We use the information about your use of the services, applications and activities on the Sites and the Applications to monitor user traffic patterns and try to analyze what our users prefer so that we can design better services, applications and activities for you. The personal information that you provide may be used to create applications and services tailored to your interests and preferences.

In a bit more detail:

Personal Information. We will use the personal information you give us to send you an email confirming your registration with the Sites and to respond to questions from you. Some areas of Sites or the Applications may require you to submit information in order for you to benefit from the specified features (such as newsletter subscriptions, tips/pointers and order processing) or to participate in a particular activity (such as sweepstakes or other promotions). You will be informed at each information collection point of what personal information is required and what information is optional. We will use your personal information to communicate with you about our products and services if you have indicated that we may do so.

IP Address. In addition to using the IP address of your computer to maintain communications with you as you move about the Sites or the Applications, we also may use your IP address to personalize content provided on the Sites or the Applications. We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use when connecting to our Sites and administer and improve the Sites. We retain IP addresses, and we retain them together with personally identifying information.

Cookies. We use the data we obtain through the use of cookies to customize your Sites and Applications experience by anticipating the information and services that may be of interest to you. We also analyze the information collected with cookie technology to help us improve the functioning of the Sites and Applications by monitoring traffic in popular areas and to modify the services and information we provide to meet customer demand. We will link the clickstream data available to us through the use of cookies to the personal information that you may choose to provide elsewhere on the Sites and the Applications. We use the information we collect through the use of cookies for our business purposes, including operation of the Sites and the Applications, as well as research and product analyses to help us better market our products. Your browser software can be set to reject all cookies, but if you reject our cookies certain of the functions and conveniences of the Sites or the Applications may not work properly. Cookies and similar technologies are how we ensure that we can promptly retrieve and deliver the information to you when you use the Sites and the Applications.

Geo-location. We may use geo-location information collected with GPS or similar technology via the Sites or the Applications in order to display a list or map with nearby Rexall, Pharma Plus, Rexall Pharma Plus pharmacy locations and contact information and the applicable services available to you. We will not share your current location with any third party.

Our Relationship to Third Parties

We have relationships with different agents and third party service providers, including PharmaSmart, who help us provide services to you, administer our business, including designing, maintaining and improving the Sites, the Applications, our systems and our computer security. We also use third parties to analyze data collected on the Sites and the Applications. We will not disclose your personal information to anyone other than our employees, our affiliates, our agents and those third parties that require such information in order to help us provide services to our and administer our business, including administering and maintaining the Sites and the Applications. When we allow a third party service provider to have access to your personal information, they will only be permitted to take it or use it for purposes that are consistent with this Privacy Statement.

We will not transfer your personal information outside of Canada.

In addition, we may disclose your personal information in connection with the sale, assignment, reorganization or other transfer or change of corporate control of our business, in which case we will require any such buyer to agree to treat it in accordance with this Privacy Statement.

Your personal information may be de-identified and in some cases aggregated with de-identified information from other Rexall customers. This de-identified information will be used to assess various factors, including trends in patient health, and adherence and compliance rates, which are useful to understand and improve upon health care services and delivery. This de-identified data may be provided to third parties for these purposes. You cannot be personally identified from the de-identified data. Rexall will never disclose personal information to third parties except as set forth herein.

Our Security Measures

We are committed to protecting the security of your personal information. We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use your personal information and have clearly defined internal policies and practices. We apply security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.

Your personal information is stored on our database servers or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Statement. We have implemented technological measures to prevent individuals from accessing personal information without authorization. Data centers are designed to be physically secure and protected from unauthorized access by unauthorized persons.

Although we will make reasonable efforts to protect personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems. Where you use passwords, ID numbers, or other special access features, it is your responsibility to safeguard them.

Information Applicable to Online Activities

The Sites and Applications are intended for users who are over 18 years of age. We do not knowingly collect or solicit personal information from children nor do we allow them to become registered users of, or to request information through, the Sites or the Applications.

If you choose to use certain features of the Sites or the Applications, you are required to establish a personal profile and register a personal account. To do so, you will need to input certain personal information into the Sites or the Applications which will be cross-checked and verified against your records maintained by your pharmacist. This registration information is used to provide and otherwise administer the Sites and Applications, and the services offered to users.

There may be links from our Sites or the Applications to other websites; note that this Privacy Statement applies only to our Sites and Applications and not to websites of other companies or organizations to which our Sites or Applications may be linked. You must check on any linked websites for the privacy policy that applies to that website and/or make any necessary inquiries in respect of that privacy policy with the operator of the linked website. These links to third party websites are provided as a convenience and are for informational purposes only. Rexall does not endorse, and is not responsible for, these linked websites.

Retention of Personal Information

In order to provide you with quality health care and in compliance with existing federal and provincial legislation, we keep a record of the medications dispensed to you or services provided to you at our pharmacy. We also include in our records any relevant health information that we require to ensure that you are not given, or advised to take, a medicine that is not appropriate for you. We will retain your personal information for the period of time that is required by law (we have to keep prescription files for a designated number of years even though the individual may no longer be a customer). When your personal information is no longer required, it will be destroyed or depersonalized.

Changes in Our Privacy Statement

If we alter our Privacy Statement, any changes will be posted on this webpage so that you are always informed of the personal information that we collect about you, how we use it and the circumstances under which we may disclose it. Please check back from time to time to ensure you are aware of our current policies.

BY SUBMITTING PERSONAL INFORMATION TO REXALL, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT. BY USING THE SITES OR THE APPLICATIONS, YOU ALSO ACCEPT THE TERMS OF USE POSTED ON THE SITES.

If you have any questions about the Privacy Statement or the handling of your personal information, please contact Rexall Pharmacy Group Ltd.. at Toll-free: 1-877-378-4100 or send an email to privacyofficer@rexall.ca to contact us. You can also contact us by mail at:

Privacy Officer
Mona Sabharwal
Rexall Pharmacy Group Ltd..
5965 Coopers Ave.
Mississauga, Ontario
L4Z 1R9

For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:

Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3

Or your provincial office of the Information and Privacy Commissioner for more information.

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