Gabriel Torani et Habib Haddad, Pharmaciens Inc. and Spec-Pharma Inc. (the “Pharmacy” or “we”) is concerned about the privacy and protection of personal information processed within its organization. We are committed to protecting your personal information collected within the framework of providing our services, when you communicate with us, or when you use our website www.spec-pharma.ca (the “website”), and we are committed to using it only for the purposes for which it was collected.

1. SCOPE AND APPLICATION
2. WHY WE COLLECT INFORMATION
3. INFORMATION WE COLLECT
4. HOW INFORMATION IS STORED AND DISCLOSED
5. HYPERLINKS AND THIRD PARTIES
6. SECURITY & RETENTION
7. YOUR RIGHTS
8. CONTACT US

This Privacy Policy (the “Policy”) governs the collection, use, disclosure, and retention of information obtained by the Pharmacy about the following individuals (collectively, “you”):

1. who register and interact with the Pharmacy as patients or clients (“Patients”),
2. who access or use the website (“Users”),
3. who apply for or perform employment with the Pharmacy (the “Employees”),
4. who act as service providers with the Pharmacy, or
5. who communicate with us, whether by email, phone, social media, or any other means.

BY ACCESSING THE WEBSITE OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU CONSENT TO THE COLLECTION, USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS POLICY.

1. SCOPE AND APPLICATION

The term “personal information” means any information that, when taken alone or in combination with other information, can identify an individual, such as its name, date of birth, email address, and any other information that must be treated as “personal information” in accordance with applicable laws.

The Pharmacy reserves the right to change this Policy at any time without notice. The current and updated version of the Policy is available on the website and its last updated date is indicated there. If changes are made to the Policy that would materially alter the risk to privacy and the protection of personal information, we will notify you by means of a notice posted on the home page of the website or we will contact you to inform you of the changes, when required by law. Your continued use of the website after any such changes become effective will constitute your acceptance of such changes. We recommend that you review this Policy regularly.

This Policy is an integral part of the website Terms of Use, which govern your use of the website.

2. WHY WE COLLECT INFORMATION

The personal information that is collected and used is for the following purposes, among other things:

• to provide our services to patients within the framework of diligent administration,
• to process user, patient, and employee requests, including requests for information regarding our services and products,
• to share information with our patients, partners, and internal service providers,
• to enable users to access and use the website properly,
• to ensure sound human resources management for our employees,
• to conduct and facilitate the sourcing, selection, recruitment, and communication of potential candidates,
• to evaluate, optimize, and improve the provision of services to patients, the products available and the functionality of the website,
• to communicate with you in relation to the activities of the Pharmacy, a problem, a request, or a need you shared, your experience with our services, or with our website,
• to track your use of the website’s features.

We only use personal information for the purposes for which it was collected.

Your health information may be used for statistical, or research purposes as required by law. This health information will then be depersonalized (your name or other identifying information will be de-identified so that it will no longer be possible to identify you or associate this information with you) and aggregated (this information will be combined with a set of information from other patients).

3. INFORMATION WE COLLECT

We collect certain personal information about you to be able to identify and contact you as needed, which you provide voluntarily, for example when you register as a Pharmacy patient. This personal information may include, as applicable, your full name, date of birth, health insurance number, or other insurance information, contact information (mailing address, email address, telephone number, preferred language), and emergency contact information, as well as certain information regarding your medical history and medication history.

Some personal information, including certain sensitive health information, may be received, or collected directly from third parties working in the health field with your consent, in particular from doctors, hospitals, or clinics who send us prescriptions directly, from patient support or assistance programs or from secure public databases such as the Dossier Santé Québec or the Quebec Vaccination Registry, all in compliance with our ethical obligations and applicable health laws.

Before, during, or following any recruitment process or provision of employment or services with us, we collect certain personal information about you so that we can identify and contact you as needed. This information is collected by the human resources team when you apply for a job with us, on job search platforms (Indeed, LinkedIn, etc.), when you onboard or update your employee file with us. This personal information may also include your social insurance number, your marital status, the name of your employer and the position held, your curriculum vitae and certain financial information for the payment of salaries and other employment benefits.

When you access and use the website, we may collect certain data about your use of the website, such as the features used, or the sections visited, or any other data that identifies the operating system of the device you are using. This data cannot be used to identify you personally. We may use performance tools provided by third parties, such as Google Analytics, to collect information that is not of a personal nature, such as the Internet browser and the type of operating system you are using and the domain name from which you were directed to the websites. Google Analytics uses cookies to collect statistical data in aggregate form to analyze how visitors use a website. These cookies are used to store non-personally identifiable information. If you do not wish to provide  information to Google Analytics, you may choose to opt out of the use or collection of your data by using the Google Analytics Opt-Out Browser Add-on available at https://tools.google.com/dlpage/gaoptout. For more information about Google Analytics and how this third party processes and manages your personal information, you can consult their privacy policy available at https://www.google.com/intl/fr-CA/policies/privacy/.

4. HOW INFORMATION IS STORED AND DISCLOSED

We retain personal information for a reasonable period to fully respond to your patient requests, to provide you with proper access to the websites, or to fulfill the purposes set out in our Policy, as required by law, whichever is longer. After this period, we anonymize or destroy them to protect them from unauthorized access or disclosure, in accordance with our ethical obligations and applicable health laws.

Only relevant Pharmacy staff members have access to personal information when it is necessary for the performance of their duties related to the services to be rendered and in accordance with the purposes set out in this Policy and our ethical obligations, subject to the following paragraph.

We never disclose your personal information to anyone outside the Pharmacy without your consent, except for the following third parties and only if they have implemented appropriate security safeguards to ensure at least the same level of security as ours:

• our suppliers who have been retained to perform certain functions on our behalf (e.g. data processing and storage, quality of service analysis, monitoring and management of applications and recruitment, etc.). In this case, we take the necessary steps to ensure that these third parties have access to only the information that is necessary to carry out the agreed services, that they process your information only for the purposes we have identified, and that they have in place personal information protection measures that comply with applicable laws and allow us to comply with the same conditions and level of protection as set out herein Politics,
• any entity in the event of a merger, corporate reorganization or change of control of the Pharmacy, in whole or in part, only if the parties have signed an agreement stipulating that the collection, use and disclosure of the information is limited to the purposes of the business transaction,
• any public authority if required by law, or to defend our rights, or otherwise in accordance with the law. If we are required to disclose information or provide a copy of such information to a government agency pursuant to any law or court order, we will attempt to notify you in advance to the extent permitted by law.

5. HYPERLINKS AND THIRD PARTIES

The website may contain sharing or publishing options or links to third-party websites or platforms. By using or activating these links or features, you leave the website, and your browsing becomes subject to the terms of use and privacy policy of these third parties. We have no control over these third-party platforms and the fact that these platforms are listed on the website does not imply any liability whatsoever.

6. SECURITY & RETENTION

All personal information and other data are stored on servers with high security guarantees, protected against non-compliant use and access by unauthorized persons. We strive to maintain the necessary physical, administrative and technical security measures at our offices and information retention centers. Personal information is only made available to individuals (employees or agents) who need access to this information to carry out their responsibilities with the Pharmacy.

We use reasonable measures to protect your personal information transmitted during your use of the website. More specifically, we use technical and organizational measures to protect your personal information from loss or theft, as well as from unauthorized access or disclosure, both internally and externally within our organization. However, no safety mechanism is perfect, and you should be aware that there is always some risk of security breaches. We will not be liable for any such information about you to be disclosed, except in the case of negligence on our part.

All data, including personal information, collected in connection with your use of the website is stored on servers located in Canada. However, this data may be processed by third-party service providers located outside of Canada to enable them to carry out mandates for us. In the latter case, we take reasonable steps to ensure that these third parties are bound by appropriate safeguards. 

7. YOUR RIGHTS

You have the right to know the purpose for which the Pharmacy collects and processes your personal information, as well as the right to access, update and correct that information. You may withdraw your consent to the use and retention of your personal information by the Pharmacy at any time, subject to our ethical obligations and applicable health laws. In such a case, however, you may no longer be able to use certain patient services or website features.

8. CONTACT US

If you have any questions about this Policy, access to your personal information or the collection, use and disclosure of personal information by the Pharmacy or how you can exercise your rights set out above, make a complaint or update your personal information, please contact our Privacy Officer as follows:

Privacy officer:	Melissa Beauvillier, Project Manager & QA Specialist
By e-mail:	mbeauvillier@spec-pharma.ca
By mail:	Pharmacie Torani et Haddad Att: Melissa Beauvillier, Privacy Officer, 8500 Decarie blvd, Suite 100, Montreal, QC, H4P 2N2

We will make every effort to process your request promptly.

Last revised: April 09, 2024