Privacy Policy

(This Privacy Policy may be modified from time to time without notice. This policy was last updated on September 15, 2014)


Introduction

We take our obligations to protect and respect you, your privacy and your personal information seriously. This page summarizes the privacy policy and practices of the RxNet.ca website. The most recent version of this Privacy Policy can be accessed on our website at any time.

For purposes of this Privacy Policy, "personal Information" means information in any form about an identifiable individual, including any information related to the physical or mental health of the individual, the health history of the individual or his or her family, the provision of health care to the individual, the identity of a health care provider providing health care to the individual, the individual's eligibility for health care coverage, medication prescribed for an individual, the individual's health care number, or any other information constituting personal health information as defined under applicable privacy legislation.

However, this Privacy Policy does not concern itself with business contact information (such as the individual's name, title and business address) and does not include aggregated or anonymized data from which the identity of any individual cannot be ascertained. We reserve the right at all times to use any such business contact information or aggregated or anonymized data in any way and for any purpose that we determine appropriate.

Consent

You can visit our website on the internet without telling us who you are or revealing any personal information about yourself. We only collect personal information about you when you specifically and knowingly provide it to us via emails or downloadable order forms. If you do provide any personal information to us, by doing so you are expressly consenting to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. We will never require you to consent to the collection, use, or disclosure of your personal information beyond what which is necessary to supply you with the services you have requested or to fulfill the particular purposes identified in this Privacy Policy.

In addition to your implied consent which you might provide as set out above, where appropriate, specific authorizations or consents may be obtained from you for certain specific products, services or communications. As well, there may also be circumstances where your consent is not required by law and in those circumstances we may act without seeking or requiring your consent. An example of a situation where your consent may not be sought or required is when the information is used or disclosed in the case of an emergency that threatens your life, health or security.

You may contact us to withdraw your consent at any time. However, it may take some time for our records to reflect these changes. For example, services or communications provided to you that are in process at the time you withdraw your consent may be unaffected by the withdrawal.

Please note that your withdrawal of consent may also mean that we may not be able to continue to offer you the services, programs or information that you requested or that would otherwise be available to you. For example, if you withdraw your consent allowing us to share your personal information with an RxNet member pharmacy, the pharmacy may not be able to fulfill your prescriptions, transmit drug benefit claims or consult with your health care providers.

As well, there are circumstances where we may be required by law to continue to contact you after you have withdrawn your consent.

Collection through use of Technology

When you visit our website or use our mobile application, we may use, and send to your device or computer, cookies, web beacons, single-pixel gifs and other technologies to help us collect and store personal information or non-personal information about you or to enable us to manage our website, diagnose technical problems, improve the content of our website, offer services and present offers to you. These technologies are used to help us understand what actions you take on our websites and mobile applications. For instance, we may store your personal information or non-personal information to enable us to populate entry fields that you have previously completed, or in order to display content
specific to your language preference or region. You may be able to delete or disable certain of these technologies, such as cookies, in your web browser or by other means, but doing so may mean that you may limit or compromise the functionality of our website or you may not be able to use some of the features of our website.

Our servers automatically log information about visits to our website in the normal course of establishing and maintaining internet connections. Server logs record statistical information, such as a visitors' IP address, the type of operating system used, the time and duration of your visit, web pages requested, and may also identify categories of visitors by items such as domains and browser types. These statistics are reported in aggregate form to our web and communications staff, and are used to improve our website and ensure that it provides the optimal web experience for visitors.

If you choose to use our mobile application, we may also receive personal information and non-personal information about your current location, your mobile device, tablet, or browser. If you choose to turn off the tracking of your location on your devices, tablets or browsers, you may not be able to use our mobile application.

As a convenience to you, our website may contain hyperlinks that, when clicked, may take you to a third party website not controlled by us. We do not endorse or verify these sites or the products or services which may be advertised on them. These hyperlinked third party websites may collect and disclose information different than our website. We are not responsible for the collection, use, or disclosure of your personal information collected through these third party websites, and we expressly disclaim any and all liability related to that collection, use, or disclosure.

Purposes

We collect, use and share personal information for the following purposes:

  1. To assist you in connection with locating or choosing an RxNet member pharmacy
  2. To respond to your inquiries
  3. To identify your needs and preferences
  4. To assist you in connection with the provision of healthcare services, such as fulfillment of your prescriptions or the administration of your health benefits
  5. To protect the rights and security of the public, our customers, our employees and RxNet member pharmacies
  6. To communicate with you as we may require for legitimate purposes, including in order to provide services requested by you, offer additional services to you or verify instructions received from you
  7. To manage our business, website and mobile application
  8. To develop market strategies and analyze market behaviour to improve our business, services, website and mobile application
  9. To comply with our legal obligations

If any additional purpose arises, we will notify you prior to using your personal information for that purpose. Unless required by law to do otherwise, in all cases, we will obtain your consent prior to collection and use of your personal information.

Disclosure

We may share your personal information with RxNet member pharmacies, your provincial drug benefit program, your private health insurance provider or claim adjudicator (as necessary in order to process your claim), your healthcare providers (which may also be referred to as your "circle of care") and your authorized family members. It may also be necessary to provide prescription-related information to regulatory authorities, government bodies or registries. We may also share it with others but only with your consent or as otherwise permitted by law. All such information sharing is done in a manner consistent with this policy.

Canadian law sometimes also permits or requires the use or sharing of personal information without consent. For example, this could occur in situations necessary to protect our employees, customers, RxNet member pharmacies or others. Should this occur, we will not share more personal information than is required.

Your personal information may also be disclosed in connection with the marketing, sale, securitization, financing or reorganization of our business or its assets. In this case, we will require that your personal information will continue to be treated in accordance with this Privacy Policy or as otherwise permitted by law.

If the relationship between us and one of our RxNet member pharmacies ceases, and if such pharmacy continues to provide you with products, services, programs, promotions or events, your personal information will be subject to that pharmacy's privacy policy and this Privacy Policy will no longer apply.

Other than as set out in this Privacy Policy, we will not give, sell, rent, exchange or loan any identifiable personal information to any third party, unless legally required to do so. However, we may share non-personal, summary, or aggregate customer data with business partners and other third parties. We may also release personal information when we believe such release is appropriate in order to comply with law; for example, if we receive a subpoena or court order to do so.

Protections

We will use reasonable efforts to protect your personal information and prevent the unauthorized access, collection, use, disclosure, copying, modification or disposal of it by implementing security safeguards appropriate to the sensitivity of that information. These safeguards will include physical measures (such as storing the information in locked filing cabinets), organizational measures (such as restricting access to offices, files and databases, as required, where information may be held, requiring security clearances and limiting access to information on a "need to know" basis, and requiring regular reviews of our processes and procedures), software and electronic measures (such as requiring the use of passwords, firewalls and encryption for electronically stored information) and investigative measures (such as conducting inspections or investigations in situations where there are reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed).

Your personal information may sometimes be stored on servers or networks provided by third party service providers. If such servers, networks or service providers are located outside Canada, then your personal information will be governed by the laws of that jurisdiction.

We will only keep your personal information for as long as is required to fulfill the purposes set out in this Privacy Policy and for a reasonable period of time thereafter in order to respond to inquiries or as may be required by law. Once we have determined that your personal information is no longer needed, it will be destroyed in accordance with our data and record retention policies.

Access and Disputes

You can request access to your personal information held by us at any time so that you can confirm the accuracy of the information in our possession.

We will try and respond to all such inquiries within 30 days of receiving the request and confirming your identity. However, you should be aware that it may not always be possible to provide you with access to your personal information or certain portions of it. For example, situations may arise where such disclosure would also have the effect of revealing to you the personal information of another customer or sensitive commercial information belonging to us or our business partners. In other cases, your personal information may be protected by solicitor-client or litigation privilege or was collected by us for the purposes of investigating or enforcing a breach of agreement or other legal contravention. Sometimes, providing you access to the information may prove to be cost-prohibitive or we may otherwise be legally prevented from providing you with the requested access. In any of these types of situations, we will inform you of our reasons for denying you the requested access.

At any time, you may challenge our compliance with this Privacy Policy or our legal requirements by sending an email to our Privacy Officer at privacy@rxnet.ca. We will investigate all complaints, inquiries and challenges and, if it is justified, we will take all reasonable steps to investigate and respond to your complaints, inquiries and challenges in a timely manner. External professional guidance may also be required before a response is made to you on any such complaints, inquiries and challenges and you will be informed of the approximate time it will take to respond in as timely a fashion as commercially reasonable. Any complaint found to be justified will be dealt with in an expedient manner.

In Ontario, the Personal Health Information Protection Act governs the collection, use and disclosure of personal health information. If you reside outside of the Province of Ontario, the Personal Information Protection and Electronic Documents Act or other legislation regarding the collection, use and disclosure of personal health information may also apply.