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Quebec Privacy Policy

Last Updated: August 23, 2021



Thank you for visiting the Quebec www.pocketpills.com (the “Website”) which is
operated by Pharmacie Steeve Benarroch (Côte-de-Liesse) Ltd. (the “Pharmacy”).
 The Pharmacy is affiliated with Pocketpills and uses the Pocketpills online
platform and mobile application (the “Platform”) under license.  Personal
Information collected pursuant to this Policy may be collected, stored and used
by both Pocketpills and the Pharmacy.  Together, we are committed to respecting
the privacy of our users and the confidentiality of the personal information
that we collect through the Website and Platform.


We are proud to show our commitment to your privacy, by complying with
applicable laws in Quebec and Canada, such as the Personal Information
Protection and Electronic Documents Act (Canada) and the Act Respecting the
Protection of Personal Information in the Private Sector, the Act Respecting the
Sharing of Certain Health Information, the Act to Establish a Legal Framework
for Information Technology, and any personal information or data requirements,
regulations or policies of the Ordre des Pharmaciens du Québec.


The purpose of this Privacy Policy is to inform you about the types of Personal
Information we collect, use and disclose in connection with the Website and the
Platform.  It explains how we use, store and disclose that information, the
choices you have regarding such use and disclosure, and how you may correct that
information.


Personal Information” is any information that is identifiable with you, as an
individual.  This information may include, but is not limited to, an
individual’s name, email address, residential address, precise geolocation
information (i.e., your specific location), telephone number, date of birth,
provincial personal health care card and number, medication and prescription
information, information regarding allergies, medical history, gender, insurance
information, payment card information, transaction history, other billing
information, occupation, employment status, and in some cases, user name and
password. When signing up for health-related services, including ordering
prescription and non-prescription drugs, Personal Information may also require
you to provide certain physical and mental health information, including but not
limited to personal and family medical history information, details of your
existing medications, existence of drug allergies, medications requested and
prescription information, the name of your primary physician and his or her
contact information, your provincial health care card number and any private
health benefits number or account information.


Consent

We may collect Personal Information from you directly and/or from third parties,
where we (and/or those third parties) have obtained your consent, or as
otherwise permitted or required by law.  By accessing the Website, downloading,
installing or using the Platform and submitting information to us through the
Platform (regardless of whether you register an account with us), you consent to
the collection, use and disclosure of your Personal Information by us in
accordance with this Privacy Policy.  Where we collect Personal Information from
you through the Platform for use and retention by the Pharmacy, that information
is subject to legal, organizational, technical, physical and contractual
confidentiality, privacy and data security safeguards.


If you connect your Google, Apple or other third-party accounts with us, we may
collect both Personal Information and non-Personal Information from those
accounts for the purpose of providing our services. This is dependent on the
privacy policies or settings for those accounts. We will not share the data
collected with any third party. You may choose to limit what data you provide to
us from such third parties by adjusting the privacy settings within those
applications.


Any information you disclose to a third party is dealt with in accordance with
the privacy policies adopted by each of those third parties. Individuals are
encouraged to review the privacy policies maintained by each of those third
parties to understand how their information will be used by them to process
requests.


If you do not wish to have us collect your Personal Information through the
Website or Platform, you can choose not to provide it. However, your decision to
withhold particular details may limit the services we are able to provide and
make it more difficult for us to advise you or suggest appropriate alternatives
to our services. If we are unable to accommodate your requests based on the
information that you have provided, we may ask for additional information so
that we may better accommodate your needs.


Subject to legal and contractual requirements, you may refuse or withdraw your
consent to certain of the purposes identified herein at any time by contacting
us through the contact details provided below. If you refuse or withdraw your
consent, you acknowledge that we may not be able to provide you or continue to
provide you with certain services which may be of value to you.


Collection of Personal Information

We may collect information (including Personal Information) as follows:

 * Information You Provide to Us. When you open an account with us, request
   support, or in any other way take steps that require the submission of
   information; we may collect Personal Information.  This information is
   necessary for verifying your identity, fulfilling your orders, contacting you
   in regards to your prescription and providing you with the information and/or
   services requested.
 * Information Provided to Us by Your Patient Representative or by a User for
   whom You will be a Patient Representative. If a user of the Website or the
   Platform wishes to have you act as the user’s Patient Representative for the
   purposes of managing the user’s prescriptions and services, we may collect
   information about you from that user, such as your name, email address,
   telephone number, date of birth and gender. If another user wishes to act as
   a Patient Representative for you, we may collect your name, email address,
   telephone number, date of birth and gender. If you are a user and you are a
   parent or legal guardian of a minor and wish to act as Patient Representative
   for the minor for the purposes of managing the minor’s prescriptions and
   services, we may collect from you the minor’s name, date of birth and gender.
   This information is necessary for verifying your identity or your Patient
   Representative’s identity, fulfilling your orders, contacting you regarding
   your prescription and providing you with the Services.
 * Social Media Sites. If you choose to connect to the Platform through a
   third-party social network (such as Facebook, Facebook Messenger or
   WhatsApp), we may collect information from your profile on such third-party
   social networks, such as your name, username, gender and date of birth.
 * Payment Information.  When you or your Patient Representative make purchases
   through the Platform, our payment processor Moneris will collect your credit
   card information.  We do not collect or store your credit card information.  
   Other information, such as your insurance information, policy numbers and
   group plan information, will be stored and processed by us or any pharmacy
   software provider we may partner with to get, and not our payment processor.
 * Prescription Information. When you or your Patient Representative fill
   prescriptions through the Platform, you or your Patient Representative will
   provide us with your prescription information, including the medication
   requested, amounts and information regarding your physician or other
   prescribing professional.  We will use this information to fill your
   prescription as required.  This information will be stored, processed and
   shared with a prescription drug information system as required by applicable
   law in your applicable jurisdiction.  We may also contact your physician or
   the prescribing professional if additional information regarding your
   prescription is required.  Some additional information obtained from your
   physician or prescribing professional may also be Personal Information, such
   as additional information regarding your medical history or medications. We
   may discuss specific medications with you or your Patient Representative on
   SMS, email, chat, phone call or any other communication.
 * In-Platform Communications. If you choose to send a message to us through our
   message, chat, post, SMS, email or other function, we may collect any
   information you may disclose through such means in order to facilitate the
   communication.
 * Push Notifications. If you choose to enable push notifications, we may use
   your information, such as a device ID or email address, in order to send push
   notifications to your device.
 * Your Location. We may collect precise geolocation information provided that,
   prior to doing so initially, you will either be informed of such practice or
   be prompted to consent to or disallow such feature. You will have the ability
   to disallow it at any time thereafter by taking the appropriate steps in the
   applicable settings tab.
 * Information You Submit to Us. If you choose to submit your information to us
   for any other reason, in any other form, we will collect such information and
   use it for the purposes for which you submitted it.
 * Visiting the Website. We will not collect any Personal Information from you
   simply by virtue of your visiting the Website; we only collect Personal
   Information if you or your Patient Representative choose to submit it to us.
   We do, however, collect non-Personal Information such as usage data, whenever
   you use the Website. Such non-Personal Information is not combined with
   Personal Information unless and until you choose to submit Personal
   Information to us.
 * Where Permitted by Law. We may also collect information, including Personal
   Information as otherwise permitted by law.
 * “Cookies”. We may also use “cookies” or similar technologies when you use or
   access our Website and/or Platform (small amounts of data that are stored on
   your computer’s hard drive, mobile device or media system platform that
   identify your computer, mobile device or media system platform and may store
   information about you, such as behavioural data). Should you choose to submit
   Personal Information to us, we may link cookie information to such Personal
   Information. If you do not wish to accept cookies, you have the option of
   blocking or disabling cookies. However, please be aware that some of our
   Website or Platform services will not function properly if you do so. Visit
   www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu,
   www.youradchoices.ca/choices, and www.aboutads.info/choices/ to learn more
   about the choices available to opt out of cookies and advertising.
 * Third Party Advertising Partners. In addition, certain advertising partners
   may also make           use of cookies in connection with advertising on
   behalf of us. Such cookies may collect non-Personal Information which those
   partners may use to serve you targeted ads both within and outside of the
   Website and Platform. We may use analytics service providers, including
   Google Analytics, to collect information regarding visitors to our Website,
   such as their behavior on our Website or information about their demographic.
   For more information about Google Analytics, see
   https://www.google.com/policies/privacy/partners/. To opt out of Google
   Analytics, visit https://tools.google.com/dlpage/gaoptout.


Use of Personal Information

We identify the purposes for which we collect and intend to use your Personal
Information at the time we collect such information from you and obtain your
consent, in any case, prior to such use. We generally use your Personal
Information for the following purposes (the “Purposes”):

 * to facilitate and administer your access to and use of the Platform;
 * to track your orders through the Platform and arrange for prescription
   fulfillment, refill and delivery by the Pharmacy;
 * to facilitate communications with third-party service providers who are part
   of your care network such as your physician or other pharmacists;
 * to facilitate communications with third-party service providers with whom we
   have a contractual relationship such as benefit providers, insurers or to
   process payment;
 * to identify opportunities for care, further service and to improve our
   services and product offerings;
 * to send you information related to our Website and/or Platform, including
   confirmations, technical notices, updates, security alerts, information
   related to product safety or recall issues and support and administrative
   messages;
 * for analytical, research, and optimisation purposes;
 * to advise you about new programs, products and services that may be of
   interest to you;
 * to conduct marketing, including promotional activities such as running
   marketing or advertising campaigns with third party marketing and advertising
   partners to promote the Pharmacy and/or the Platform;
 * to respond to your inquiries, complaints or requests;
 * to investigate and respond to legal claims;
 * other such purposes for which we may obtain consent from time to time; and
 * other uses as may be permitted or required by applicable law.


Disclosure of Personal Information

Generally, we will only disclose your Personal Information to third parties
where you have provided your consent for us to do so or where we are permitted
or required to do so by law. We will not transfer your Personal Information to
third parties, except for our subsidiaries, affiliates and business partners
that we engage to provide services on our behalf, such as (but not limited to)
web hosting services, credit card payment processing, provincial/private health
plan coverage, pharmacy software providers, order processing and delivery,
provided that such third parties have agreed to comply with legally required
privacy standards and applicable law, and to use the information only for the
purposes disclosed at the time of collection or for a use consistent with that
purpose. We will only provide those third parties with the Personal Information
that they need to deliver the services to you or us.  Notwithstanding the
foregoing:

 * We may also make disclosures of Personal Information to a potential acquiror
   in connection with a transaction involving the sale of some or all of the
   business (in which case the use of your Personal Information by the new
   entity would continue to be limited by applicable law).
 * We may disclose Personal Information where otherwise permitted or required by
   law.


We may also share aggregate or anonymized information, including de-identified
Personal Information, about you with service providers, business partners, and
other third parties, to the extent permitted by applicable law.


We may sell, rent or share your usage data and other non-Personal Information
including, without limitation, device IDs, advertising IDs or other persistent
identifiers and non-precise geolocation information or precise geolocation
information (if you choose to allow us to collect it), with third parties who
assist us with our operations (such as administration, analytics, research,
optimisation), and with our business partners in order to, among other things,
allow them to serve more relevant advertisements tailored to you.


Storage and Retention of Personal Information

We will securely store your Personal Information at the Pharmacy location and/or
at our service provider’s data centres in Canada.  As some of our third-party
service providers may retain and store information received from you (including
Personal Information) outside of Canada, your information may be subject to
foreign laws and in certain circumstances foreign governments, courts, law
enforcement agencies, regulatory agencies or security authorities may have
access to your information.


All data is stored with reasonable administrative, physical and technical
security measures to protect the information from unauthorized access and
against loss, misuse or alteration by third parties.  No method of transmission
over the Internet, or method of electronic storage, is 100% secure.  While we
attempt to ensure the integrity and security of our network and systems, we
cannot guarantee that our security measures will prevent third-party ‘hackers’
from illegally obtaining access to this information.  


We will use, disclose or retain your Personal Information for as long as
necessary to fulfill the purposes for which it was collected or as permitted or
required by law.  Personal Information is retained in accordance with applicable
laws and any applicable document retention requirements imposed by the Ordre des
Pharmaciens du Québec or by law.


Our Policy Regarding Children

We recognize the privacy interest of children, and our Website, Platform and
services are not intended for children under the age of fourteen (14) and we do
not target our Website, Platform or services to children under that age.  We do
not knowingly collect or use any Personal Information from children under the
age of fourteen (14) unless provided by a parent or legal guardian using the
Website and/or Platform on behalf of such child. If a parent or legal guardian
becomes aware that his or her child has provided us with information without
their consent, please contact us at privacy@pocketpills.com and we will ensure
all information about such child is deleted.


Accessing and Correcting Personal Information

It is important that the Personal Information we have is accurate, complete and
up to date.  You are encouraged to inform us when there are any changes to your
information by updating your information within the Platform.  You may also, at
any time, contact the Pharmacy or the Privacy Officer at Pocketpills (the
affiliated provider of the Platform) directly to request access to your Personal
Information, verify its accuracy and, if required, to correct it.  The Pharmacy,
and its affiliate, Pocketpills, will provide you with access to your Personal
Information, except where prohibited by law from doing so, or where permitted by
law to restrict your access and have legitimate reasons for doing so.


You may contact the Pharmacy at:


Pharmacie Steeve Benarroch

105-8550 Chemin de la Côte-de-Liesse

Saint-Laurent, QC H4T 1H2

P: (514) 419-1878 F: (514) 419-1997


Or


You may contact the Privacy Officer at Pocketpills at privacy@pocketpills.com


We reserve the right to revise this Privacy Policy at any time. We will give you
notice of such revisions by posting the revised Privacy Policy on the Website.
It is your responsibility to ensure that you are aware of the current Privacy
Policy when you access or use the Website or Platform. If you continue to access
or use any of the Website or Platform after any revisions to this Privacy Policy
are posted, you will be deemed to have accepted those revisions.

PHARMACY STEEVE BENARROCH AFFILIATED TO POCKETPILLS

ONLINE PHARMACY DELIVERING TO:

Quebec



105-8550 Chemin de la Cote-de-Liesse, Saint-Laurent, QC

Accreditation #: 210682
Pharmacy Manager: Steeve Benarroch

PHARMACY OPERATING HOURS

Mon - Fri | 9:00 AM - 5:00 PM, ET

1-855-774-0104

equipecareqc@pocketpills.com

Fax: 1-855-774-0105

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