Privacy Policy
Last updated: August 22, 2023
Commitment to Privacy
Affirming Care Pharmacy is committed to protecting the privacy and security of the personal information and personal health information of our clients, patients and customers. This Privacy Policy describes how Affirming Care Pharmacy and its related companies and affiliates including, but not limited to, Affirming Care (AB) Ltd. and Affirming Care (ON) Ltd. among others (collectively, “Affirming Care Pharmacy”, “we”, or “us”) collect and use personal information and personal health information.
To demonstrate our commitment to your privacy, we comply with applicable laws and regulations thereunder. This includes the Personal Information Protection and Electronic Document Act (“PIPEDA”), Alberta’s Personal Information Protection Act (“PIPA”), Alberta’s Health Information Act (“HIA”), and Ontario’s Personal Health Information Protection Act (“PHIPA”). We believe that an important part of protecting privacy is to provide clear, and easily accessible details about how we handle user’s Information.
We reserve the right to amend the Policy at any time to account for changes in the Applicable Law and our practices. Please check to see if we have amended the Policy since you last used our services to ensure you are aware and agree to our current privacy practices.
Personal Information and Personal Health Information
For purposes of this Privacy Policy, personal information and personal health information means any information about an identifiable individual, as may be defined or limited under applicable privacy legislation (collectively “Personal Information”). Personal Information also includes information about an identifiable individual which relates to the provision of health services to that individual, their physical or mental health, family health history, identities of an individual’s health care providers and substitute decision makers. Personal Information excludes anonymous or deidentified data or any data that is not associated with an identifiable individual.
Purpose
Affirming Care Pharmacy collects, uses, discloses, and retains Personal Information in order to provide high quality healthcare services including pharmacy services, delivery services, access to patient support programs, insurance & reimbursement services, and other services. We also collect, use, disclose, and retain Personal Information in order to meet legal and regulatory requirements in relation to the foregoing, improve our products, services or programs and for such other purposes as identified typically at or before the time the Personal Information is collected.
Consent
You have the right to determine how your Personal Information is collected, used or disclosed. Unless permitted or required by law, Affirming Care Pharmacy will not use or share Personal Information without obtaining consent. Consent may be “express” when provided orally or in writing or may be “implied” by your conduct. For most healthcare purposes, your consent is implied because of your consent to treatment; however, in certain circumstances express consent will be obtained.
If we need to use your Personal Information for an unrelated purpose, we will provide notice to you and, if required by law, seek your consent. We may use your Personal Information without your knowledge or consent when required by applicable law or regulation.
You may withdraw consent at any time, subject to legal or contractual restrictions and provided reasonable notice is given. An Affirming Care Pharmacy representative will inform you of the implications of such withdrawal.
Collection and Use
Affirming Care Pharmacy collects personal health information when you provide us with a prescription to be filled, pay for a prescription, purchase, order, return or exchange products at our pharmacy, receive clinical services, speak to a pharmacist to receive counselling and advice and/or contact us with a comment, question or complaint relating to one of our pharmacies. This information may be collected in the following ways:
From You: You may provide us Personal Information in person, over the telephone, by text message, by email or facsimile, through our website, or in any other direct manner.
From Your Circle of Care: Members of your circle of care including health care providers may provide us Personal Information about you.
When you provide us with a prescription, we may collect personal information such as your first and last name, address, e-mail address, telephone number, date of birth, gender, medical history, medical conditions, drug allergies, name of prescribing physician, personal characteristics, additional information on the prescription (such as diagnosis or instructions from the prescribing physician), provincial drug benefit program or private health insurance plan information and other information which you may provide to us to assist us in dispensing. We collect this information to correctly dispense your prescription medication (including proper dosage and instructions) as well as to identify you, to ensure the accuracy of our records, to ensure that there are no adverse drug or allergic reactions to any of the medications dispensed, to facilitate any call back, reminder or notification programs we may have in place, third-party benefit administration and patient support platforms and to comply with applicable professional, legal and regulatory requirements.
When you contact us in person, over the telephone, by text message, by email or facsimile, through our general contact submission or automated customer service response platform on our website, or in any other direct manner with a comment, question or complaint relating to one of our pharmacies or a prescription, you may be asked for information that identifies you along with additional information we need to help us promptly answer your question or respond to your comment or complaint. The information we collect, including that which may be voluntarily provided by you for these purposes, may include your name, address, phone number, personal health information, prescription information and additional information to assist us in addressing your comment, question or complain. We may retain this information to assist you in the future and to improve our product and service offerings.
When you complete our prescription transfer or refill form located on our website, you may be asked for information that identifies you along with additional information we need to help us fulfill your request. The information we collect, including that which may be voluntarily provided by you for these purposes, may include your name, date of birth, address, phone number, email, transferring pharmacy information, personal health information, prescription information and any additional information required to (i) assist us in processing your prescription transfers, refills and transactions with Affirming Care Pharmacy; (ii) contact you with respect to your prescription(s) and (iii) send you updates about your prescription status and reminders.
The collection of Personal Information is limited to that which is necessary for the purposes identified by Affirming Care Pharmacy.
Sharing Information
We will only disclose Personal Information to third parties where required by law or to our employees, contractors, designated agents, members of your circle of care, pharmaceutical manufacturers, insurance benefit providers and administrators, public payers, government agencies and other pharmacies in order to fulfill your request to transfer a prescription to or from Affirming Care Pharmacy, or third-party service providers who require it to assist us with administering our engagement with you, including third-party service providers who provide products, services or programs to us or on our behalf. Third-party service providers include, but are not limited to, providers of: payment processing gateways and administration such as Moneris, third-party benefit administration and patient support platforms such as OkRx, email or text message reminders, patient satisfaction surveys, or technology systems or applications. These third-party service providers may be located outside of Canada.
When you submit your credit card, banking and other billing information in person, over the telephone, by text message, by email or facsimile or on our website, it is captured by our third-party payment processor, Moneris, who is responsible for the storage and protection of such Personal Information. You may review the Moneris Privacy Policy here: https://www.moneris.com/en/Privacy-Policy.
We may also disclose Personal Information for the following additional purposes where permitted or required by applicable law:
To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose Personal Information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum Personal Information necessary for the specific purpose and circumstances.
During emergency situations or where necessary to protect the safety of persons.
If a business transfer or change in ownership occurs.
For additional purposes with consent where such consent is required by law.
Affirming Care Pharmacy is not responsible for the actions of any third parties, the content of their websites, the use of information you provide to them or any products or services they may offer. 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 those entities to process requests.
Website Data
Affirming Care Pharmacy collects information that an individual’s browser sends whenever they visit our website (“Log Data”). This Log Data may include information such as the computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our website visited, the time and date of the visit, the time spent on those pages and other statistics. In addition, we may use third party services that collect, monitor and analyze this type of information in order to increase our website’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to an individual’s browser from a website and stored on the computer’s hard drive. We use cookies to collect information. Individuals can instruct their browser to refuse all cookies or to indicate when a cookie is being sent. However, if an individual does not accept cookies, they may not be able to use some portions of our website.
We may employ third party companies and individuals to facilitate our website, to provide the website on our behalf, to perform website-related services or to assist us in analyzing how our website is used. These third parties may have access to an individual’s Personal Information only for the purpose of performing the above-mentioned tasks on Affirming Care Pharmacy behalf and are obligated not to disclose or use the Personal Information for any other purpose.
At times we may make content or services available from links located in this site. This may include other affiliated or co-branded websites. These other websites are not subject to this privacy policy.
We recommend that individuals review the privacy policy on each such website to determine how that site protects user’s privacy.
Security
Affirming Care Pharmacy has implemented appropriate physical, technical, and organizational security measures designed to secure Personal Information against accidental loss and unauthorized access, use, alteration, or disclosure. We protect Personal Information regardless of the format in which it is held. The nature of the safeguards varies depending on the sensitivity of the Personal Information that has been collected, the amount of information collected, the extent of the distribution of information, the format of the information and the method of storage.
Some of the methods we use to protect Personal Information are:
Physical measures, for example, time-delay safes, locked filing cabinets and restricted access to the pharmacy dispensary, storage rooms and offices; and
Organizational measures, for example, limiting access on a “need-to-know” basis; and
Technological measures, for example, computer firewalls, encryption, usernames and passwords according to assigned authorization levels.
In addition, we limit Personal Information access to those employees, agents, contractors, and other third parties that have a legitimate business need for such access.
Affirming Care Pharmacy makes its staff and agents aware of the importance of maintaining the confidentiality of Personal Information. As a condition of employment, appointment, or agency, all Affirming Care Pharmacy staff and agents must sign the Affirming Care Pharmacy confidentiality agreement and are oriented and trained on our privacy practices. In addition, those with access to electronic health records must sign individual User Agreements with the electronic health record solution provider.
Our privacy practices are intended to comply with applicable privacy laws, including without limitation, HIA, PIPA, PHIPA and PIPEDA. We will maintain the privacy and security of your Information as required by applicable privacy laws, including without limitation, HIA, PIPA, PHIPA, PIPEDA and the regulations under those Acts.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Information, we cannot guarantee the security of your Information transmitted to our Website. Any transmission of Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, contractual, or reporting requirements. Under some circumstances we may anonymize Personal Information so that it can no longer be associated with an identifiable individual. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice.
Where We Keep Personal Information
In general, we store, access and use Personal Information in Canada. Unless there is a legal or regulatory requirement to keep such information in Canada, Personal Information may also be stored, accessed, or used outside of Canada. For instance, when we engage a service provider outside of Canada, Personal Information may be stored, accessed or used in the country where the service provider is located, or from which it provides services. Where Personal Information is located outside of Canada, it is subject to the laws of that jurisdiction.
Accuracy & Correction of Personal Information
Affirming Care Pharmacy endeavors to ensure that Personal Information collected and used is accurate, complete and up to date. We encourage you to update the information provided to us, such as providing a new mailing or email address, a name change, or a change in the medical condition(s) that you have notified us about. This will help us continue to provide services to you that best meets your needs.
You may request the opportunity to review and correct your Personal Information. In very limited circumstances, we may decline access to Personal Information such as where the information requested would reveal Personal Information about someone else. Our policy is to respond to access requests as required by applicable laws. We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. If there will be charges for us to retrieve or provide you with specific information that you have requested, we will advise you of the charges that you would be responsible for and obtain your authorization before proceeding.
Your Rights
You have the right to:
Make a written request to access your Personal Information,
Request us to restrict our use or disclosure of your Personal Information,
Object to our use or disclosure of your Personal Information,
Request that we edit, but not remove, certain information (like an e-mail address),
Request that we transfer to another organization the Personal Information you have provided us, and
Request us to delete the Personal Information we hold about you.
Affirming Care Pharmacy will fulfill such requests in a reasonable period of time and in accordance with applicable laws, rules and regulations.
Further Information
Affirming Care Pharmacy encourages you to review this policy periodically. You may contact Affirming Care Pharmacy with any complaint, question, concern, or compliment relating to our information handling practices. All inquiries will be investigated thoroughly, and if found to be justified, appropriate corrective measures will be taken, up to and including revising our current policy and practices.
If you have any questions or concerns about your Personal Information, or if you would like more information about our policies and practices for managing and handling Personal Information, you are invited to contact your main Affirming Care Pharmacy contact. If your privacy concerns cannot be addressed to your satisfaction, or you wish further information, your inquiry will be forwarded to our Privacy Officer.
You may contact our Privacy Officer directly at:
Mail: 230, 510 5th St. SW, Calgary, AB, T2P 3S2 Canada
Email: privacy@affirmingcare.ca