Privacy Policy

1. Our Privacy Philosophy

We value the trust that you have placed in our business and are committed to prioritizing your privacy.  MediPharm Labs Inc. is committed to making sure you are fully informed and affirms our commitment to maintaining the accuracy, confidentiality, and security of personal information.  This privacy policy (the “Policy”) sets out the principles and practices which we will use in protecting personal information that you provide to us. Read through this Policy so you understand how we use, share and store your data.

2. Our Policy

In this Policy “we” or “us” refers to MediPharm Labs Inc. (“MediPharm”) and our affiliates and subsidiaries. All services mentioned are services and interactions provided by MediPharm.

“You” refers to anyone who visits our website(s), our clients, customers, individuals with whom we do business, and anyone who engages with our services.

For the purposes of this Policy, “personal information” means information that can identify an individual directly or is information about an identifiable individual. This does not include business contact information that is used for the purpose of communicating or facilitating communication with such individual in relation to their employment, business, or profession. Non-identifiable information, in other words, information about an individual where the personal identifiers have been removed, so that it is impossible to determine the identity of the person to whom the information relates, is not considered to be personal information.

3. Obtaining Your Meaningful Consent

The collection and use of personal information normally requires the consent of the person giving the information. However, consent requirements vary depending upon the circumstances in which the information is collected and the purposes that it will be used for. In many instances written consent is not required and may be implied where it is reasonable to do so.

Similarly, there may be situations where consent will be legally deemed to have been given. From time to time, we may collect or use your personal information for purposes not specified in this Policy, in which case we will obtain your written consent, if we are legally required to do so. By providing personal information to us when purchasing our products or services, using our website, or engaging with our social media, you are consenting to our use, collection and disclosure of your personal information in accordance with the terms of the Policy.

Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to our collection, use and disclosure of personal information in accordance with this Policy.You have the right to withdraw your consent from us collecting and using your personal information, but this may limit our ability to provide you with some of our products or services.

4. Types of Information Collected

The type of information that may be collected includes but is not limited to:

• Contact information: including your name, mailing address, email address, telephone number, and language preference

• Demographic and marketing information: including information such as your age, education, occupation, marital and family status, information on your preferences, interests, purchasing intentions, experience with competitor products and services, information on products you use, lease or own, or services which you use or subscribe to

• Applications & other online activities: we may collect information through software applications made available by us or when you otherwise use our online services or platforms, including social media platforms. We may collect information typically gathered though websites and applications, such as browser and device information, application usage data, information collected though cookies, pixel tags and other technologies, and IP addresses (refer to the section on Cookies below).

• Product feedback: we may collect information that you voluntarily provide to us through our website or other software applications via customer service or customer feedback forms. We may collect information such as the product you’ve purchased, where you purchased it, the retailer you purchased it from, inquiries or concerns that you have with regard to the product, comments that you provide to us with regard to our products, and purchase receipts that you voluntarily provide to us.

• Payment information: including your credit or debit card details, bank account information, and payment or other information required when you make a purchase

• Computer information: this includes information like device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behaviour, length of time spent on the services, and frequency of use

• Other information you voluntarily provide to us, our employees, or our contractors

We won’t take more information than we need, and you decide how and what you want to share.

5. Why We Collect Your Information

W collect and use personal information for reasons like:

• Providing services and product management – maintaining and improving our products and services, training and quality control, and otherwise running and managing our business in the ordinary course

• Client and vendor communication – newsletters or other communications to which you have subscribed or may be interested

• Regulatory requirements – complying generally with privacy laws and all other applicable legal and regulatory requirements

• Business development and market research – we use data to understand demographics, interests, usage patterns, and other characteristics of customers and recipients, purchase behaviour, purchase preferences, and to track and analyze trends and patterns

• Customer support – assisting you when you contact our customer support services, including to direct your questions to appropriate individuals, investigate and address any of your concerns, and to improve and monitor our customer support responses

• Safety and fraud prevention – to ensure safety and security, protect against and prevent fraud, unauthorized transactions, claims, liabilities, manage risk exposure, conduct investigations, to comply and enforce legal requirements and industry standards

We will obtain your consent before proceeding with any other purpose not identified in this Policy.

6. How We Collect Your Information

Personal information may be collected in a number of ways, including: in person, by mail, our Website, by email, on the internet, in our applications or other software, through authorized intermediaries, and from third parties whom you have authorized to disclose personal information to us.

If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.

• Cookies
  Our website makes use of cookies to collect information such as the type of browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique alphanumeric identification number that identifies the visitor's browser, but does not capture any personally-identifiable information. Our website automatically collects non-identifiable personal information on an aggregated basis. For example, we may track the total number of visitors to our website during a 24-hour period, but this information does not allow us to personally identify individual visitors.  You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Site.

• Phone Calls
  For the purpose of maintaining quality service, telephone calls to our customer service lines may be recorded.  If your call is subject to a quality assurance program, you will be advised prior to speaking with a representative.

• Social media
  If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Website or other applications, your communications may be viewable by the public.

• Our Website
  Our Website can be browsed without you providing us with any personal information. However, when using our Website, we may collect the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access our Website, the Internet address of the Website from which you linked directly to our Website, the operating system you are using, the sections of the Website you visit, the Website pages read and images viewed, and the content you download from the Website. This information is used for Website and system administration purposes, to understand Website activity and to improve the Website.

7. Who We Share Your Information With

We may share your information with third parties to support with providing our services. These include:

• Contractors and affiliates – companies we use for storage processing, deliveries, distribution and transport services, product services

• Administrative and technical support – cloud storage providers, data analytics providers, IT service providers, administration services

• Payment providers – we do not store your payment information for online purchases with debit/credit cards, this is shared directly with our third party payment provider

• Parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets

If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.

8. Limiting the Collection, Use and Disclosure of Your Personal Information

We do not sell personal information.

We will not use or disclose any collected personal information outside of the purposes described in this Privacy Policy unless you have otherwise consented or it is required or permitted by law. Any information shared will only be shared to the extent that is reasonably necessary.

Only the information specifically requested is disclosed and we take precautions to ensure that the authorities that are making the disclosure request have legitimate grounds to do so.

• Sharing information when legally required or permitted
  ‍We may also disclose personal information in situations where we are legally required or permitted to do so.  These situations may include criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk.

• Retention
  ‍We will store your information only for as long as what is reasonably necessary to fulfill the purpose for which it was collected. Once your information is no longer needed, we will securely and effectively dispose of it.

• Keeping your information accurate
  ‍We make every reasonable effort to keep your personal information as accurate, complete and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records.
  
  Despite our efforts, errors sometimes do occur.  Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis.  In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
  
  You can access and correct your personal information by sending a written request to our Privacy Officer at the address indicated below. At the time of your request, we may request you to provide specific information in order to permit us to verify your identity. In the event that any of your personal information is found to be incomplete or inaccurate, we will take reasonable steps to correct your personal information record.
  
  Please note that there may be instances where we may not be able to permit you to access or correct your personal information.

9. Protecting Your Personal Information

You may contact us to find out the personal information we have collected, how it has been used and any third parties with whom it has been shared. We make reasonable efforts to maintain accurate information, but you may provide any necessary updates or additions. Inaccurate information will be amended and communicated to third parties when appropriate.

Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees or contractors with legitimate business reasons (i.e. employees or contractors facilitating deliveries).

Our employees and contractors understand the importance of keeping your information private.  All employees and contractors are expected to maintain the confidentiality of personal information.

• Sharing information when legally required or permitted
  You may withdraw your consent for our use and collection of your personal information at any time, however this may limit the services and products we can provide.
  
  You may opt out of use of cookies through your browser settings.
  
  You can opt out of targeted ads served via specific third party vendors by visiting the Digital Advertising Alliance’s Opt-Out page or the Network Advertising Initiative’s Opt-Out page.
  
  If you do not want to be contacted for product, service or marketing purposes, or if you want to be removed from our direct marketing programs, telemarketing, direct mail or e-mail lists, please contact our Privacy Office as indicated below. Except as required or permitted by applicable laws, you have the right at any time to withdraw your consent to our collection and use of your personal information. We will take steps following receipt of your written request to amend our records to reflect your request.

• Safeguarding your information
  To ensure that your personal information is protected, we utilize security safeguards that are on par with the industry standard.  We keep electronic customer files in a secured environment with restricted access and use.
  
  Please note that in certain circumstances such as matters relating to law enforcement and public or personal health, safety, security or property, or for the purpose of collecting monies owed to us, applicable laws may require or allow us to collect, use or disclose your personal information without your consent. In such circumstances, we will only disclose your personal information to the extent that it is required.

10. Updating this Privacy Policy

We strive to evolve to meet our customer’s needs and expectations and that means our products and services may change and how we offer our products and services may changes.  With that in mind, we review our privacy practices from time to time, and that our information handling practices may change. If we make a material change to this Policy, we will post a notice on our Website and highlight the changes. We may also notify you by email. Material changes to this Policy will be binding after such changes have been introduced and for which notification of such material changes has been made. You may determine when this Policy was last updated by referring to the date found at the bottom of this Policy. If at any point you do not agree with the terms of this Policy, you must not use our services.

11. Website and Apps Governed by this Privacy Policy

Our Website and any of our applications available from our Website or third party platforms are governed by the provisions and practices stated in this Policy.  Our Website and such applications may contain links to third party sites or applications that are not governed by this Policy.  Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Website or such applications, and that we are not responsible for the privacy practices of third party sites or applications.  We therefore suggest that you closely examine the respective privacy policies of third party sites and applications to learn how they collect, use and disclose your personal information.

12. Governing Law

This Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.

13. Personal Information Outside of Canada

Personal information provided to our affiliates, service providers, contractors,  and others in accordance with this Policy, may be stored outside of Ontario and outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions.  For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.

14. Addressing Your Inquiries and Concerns

We are happy to provide you with a copy of this Policy and to discuss any of its content with you.

For information on MediPharm’s privacy practices, or if you have any questions, concerns or complaints, please email our Privacy Officer at: Legal@medipharmlabs.com

Last revised Thursday, July 1, 2021