We are committed to protecting your privacy, by complying with applicable privacy laws in Canada, and specifically the Personal Information Protection and Electronic Documents Act (Canada) and the applicable provincial legislation, such as the Personal Health Information Protection Act (Ontario) and the regulations thereunder.
2. THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
- Personal contact details such as your name, title, address(es), telephone number(s), and email address(es).
- Date of birth.
- Physical characteristics such as your age, weight, height and gender;
- Health insurance information, if applicable;
- Our site user names and passwords.
We collect Identity Information provided voluntarily by you. For example, when you register with or use our Site to buy medication (by entering your name and address when providing prescription details or completing and submitting our online medical consultation questionnaire for review).
We also collect Identity Information when you contact us (by email, telephone including SMS or otherwise) to ask a question or request information.
When you log in to your account through the Site, we automatically collect information about your use of the Site including details of your visits such as pages viewed and the resources that you access. This information will include traffic data, location data, IP address, browser, operating system, referral source, length of visit, clickstream data, and other communication data.
We collect System Information when you interact with our Site.
Personal Health Information
You may choose to enter or upload your Personal Health Information to our Site. Personal Health Information is a sensitive category of Personal Information that includes information relating to the provision of health care. Subject to your explicit consent or where we are legally permitted to process such data for health or legal purposes, and subject to relevant conditions and safeguards, we will also collect, use, and share your Personal Health Information, including your prescription requirements, your medical history, and the medical history of your family, where appropriate. The Personal Health Information we collect and use will be kept confidential and will never be used for direct marketing purposes without your explicit consent.
3. HOW WE WILL USE YOUR PERSONAL INFORMATION
Providing our services
As part of the provision of our services, we use the Personal Information that we collect from you to:
- facilitate and administer your access to our Site and your use of the Site’s functionality;
- register you as a user of our services;
- process and track your orders and provide your details: (a) to our HCPs to assess your medication needs and to determine whether it is clinically appropriate to diagnose you and subsequently prescribe appropriate medication; and (b) to the pharmacies to enable the pharmacies to dispense the medication to you and process your payment and / or insurance plan, if applicable;
- contact your family physician if one of our HCPs determines it is in your best interests to do so. If you provide us with the contact details for your family physician we, or our Partners, may contact them to discuss your diagnosis or prescription, where applicable;
- provide you with our helpline for and enquiries, complaints, or requests relating to your use of the Site and its services and orders placed by you;
- manage our relationship with you (for example, to notify you of any issues, or any advisory cautions we receive from suppliers or pharmaceutical companies in relation to any medication or products you have ordered through our Site, to notify you of any changes to our terms or to ask for feedback on our service); and
- investigate legal claims or such other causes as may be permitted or required by law.
We may also use the Personal Information that we collect from you for other purposes for which we may obtain consent from time to time and as may be required or permitted by applicable provincial or federal laws.
Monitoring, administering, improving, and storing
We may use your Personal Information to help us to monitor our performance, administer, and improve our service by:
- tracking and analysing activity to identify patterns and help us improve our Site and communications;
- troubleshooting, conducting data analysis, testing, system maintenance, support, reporting, and hosting of data;
- using data analytics to improve customer relationships and experiences;
- analysing information so that we can prioritise features that are relevant and popular;
- educating, training and developing our staff’s performance;
- ensuring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and
- preventing fraud.
We may also use your Personal Information for other legitimate commercial purposes, such as business administration, management and planning, accounting, and auditing.
With your prior explicit consent, or where permitted by law, we may use your Personal Information to send you information about goods and services offered by us, which may be of interest to you. If you wish to withdraw your consent at any time, please contact us at [email protected].
4. OUR PARTNERS’ USE OF YOUR PERSONAL DATA
4.1 The Pharmacies
Our pharmacies are registered in Canada and are licensed to practice pharmacy by the applicable regulatory authority in the province or territory of Canada where they practice (i.e. the Ontario College of Pharmacists). Please note that the pharmacies will be the contracting party in respect of the sale of your ordered treatment (if approved by one of our HCPs).
How the Pharmacies will use your Personal Information
In providing its services, the pharmacies will use Personal Information we share with them to:
- manage its relationship with you (for example, by dealing with any queries you raise).
4.2 Our Healthcare Practitioners
How our HCPs will use your Personal Information
In general, as part of the provision of their services, the HCPs will use Personal Information we share with them to:
- assess your health information to make a diagnosis, if applicable, and to determine if treatment is clinically appropriate, and if so, to write your prescription; and
- contact you using your provided contact information in the event that they require better and further information about you or your health condition.
The period your Personal Information will be stored by our HCPs will be determined in accordance with the relevant laws and guidance issued by the applicable professional regulatory body.
4.3 Our Helpline
5. OUR GROUNDS FOR PROCESSING
- to perform the contract we have entered into with you;
- our legitimate interests (or those of a third party) and only if your interests and fundamental rights do not override those interests; and
- to comply with a legal or regulatory obligation.
6. ONLINE COMMUNICATIONS
Please be aware that communications over the Internet, such as emails and online messages are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the Internet. All reasonable steps are taken to ensure your Personal Information is kept secure from unauthorised access, but we cannot guarantee it will be secure during the transmission process because it is not under our control. We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our control.
Any communications that involve a higher level of sensitivity should be sent to us via the messaging platform available on the Site, and not over email.
We believe that we have appropriate policies, rules and technical measures to protect the Personal Information that we have under our control (having regard to the type and amount of information) from unauthorised access, theft, improper use or disclosure, unauthorised modification, unlawful destruction, or accidental loss.
7. DISCLOSURE OF YOUR PERSONAL INFORMATION
- to another legal entity on a temporary or permanent basis, in connection with a business transaction, such as a merger, financing, acquisition, or sale of some or all of our business (in which case the new entity would continue to be bound and limited by applicable privacy law);
- where we are required to do so by law or applicable professional standards; and
- where you have provided your consent.
8. INTERNATIONAL TRANSFER OR PERSONAL INFORMATION
9. PERSONAL INFORMATION STORAGE, SECURITY AND RETENTION
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used, altered, disclosed, or otherwise accessed in an unauthorised way. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will store the Personal Information we collect from you at the Planet Medical Limited offices or third party service providers’ data centres, located in Ireland.
10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
Under certain circumstances, you may have the right to:
- Request access to your Personal Information at any time. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it. You can regularly access information about your account as well as your preferences by signing in to your account and looking under “My Account”, or by contacting us at [email protected]. You will be required to request any access you would like to information or notes made by one of our HCPs about your questionnaire or consultation as this information is not in the care or control of us.
- Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it or where inaccurate information remains on your profile.
- Withdraw consent you had previously given at any time, where permitted by law. We will then apply your preferences.
- Request the transfer of your Personal Information to another party.
- Request removal from our distribution list so as not to receive any direct marketing communications from us, as indicated in “Contact Us” section or by following the “Unsubscribe” link or the withdrawal instructions provided in our communications.
We will process your removal request immediately, and in any event within 10 business days. It can sometimes take a few days to process your removal request, and it is possible that you may continue receiving promotional or marketing emails or postal letters during this time. Your refusal to receive direct marketing messages does not prevent us from providing you with other types of non-promotional messages, such as email confirmations of transactions.
We will attempt to respond to any other written request for access to your Personal Information, or otherwise, within 30 days of receipt of your request. We will advise in writing if we cannot meet your request within 30 days. If you have a complaint with respect to this time limit, you have a right to make a complaint to the Information and Privacy Commissioner of your province of residence or the Privacy Commissioner of Canada.
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances where in our sole discretion, we deem it necessary.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.
If you wish to exercise your rights in relation to the processing of your information by any of our Partners, you should email us at [email protected]
11. LINKED WEBSITES OR APPLICATIONS
We are not responsible for the privacy policies and practices of other websites or applications even if you accessed the third party website or application using links from our Site. We recommend that you check the policy of each website or application you visit before deciding whether to proceed or disclose Personal Information to them. You should contact the owner or operator of such website(s) or applications(s) if you have concerns or questions.
13. JURISDICTION AND APPLICABLE LAW
14 OTHER IMPORTANT TERMS
14.4 If we delay in taking steps against you if you are to breach this contract, that will not mean that you do not have to do what we ask to remedy your breach and it will not prevent us taking steps against you at a later date.
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Last modified: 5 May 2022