Any patient, agent, or other third party (the “User”) in the course of its dealings with Sentrex Pharmacy Group Inc. (“Sentrex”) or otherwise, acknowledges that when visiting the Sentrex website at http://sentrex.com/ (the “Website”), or other online resources maintained by Sentrex, the User may provide Personal Information and/or Personal Health Information to Sentrex (as such terms are defined below).
“Personal Information” is defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card or information that is available in public records. Personal Information includes, but is not limited to, a User’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, interests, browsing preferences, web logs, Internet protocol addresses, network and server particulars, and/or other information relevant to the Website, promotional and marketing activities.
“Personal Health Information” is more specific, and is defined in the Personal Health Information Protection Act, 2004 (Ontario) (“PHIPA”) as identifying information about an individual which relates to that individual’s physical or mental health, the provision of health care to that individual, payments made or eligibility for health care or health care coverage of that individual, organ, tissue and fluid donations made by that individual, that individual’s provincial health card number and the identit(ies) of that individual’s substitute decision-maker(s).
Moreover, as a pharmacy, Sentrex is subject to the more stringent obligations imposed by PHIPA to the extent Personal Health Information is collected, used and disclosed. Where these more stringent obligations apply, Sentrex will abide by these higher standards.
Any Personal Information collected or disclosed without the consent of a User will only be collected or disclosed in limited circumstances that are expressly permitted by law. For example, privacy legislation permits the collection or disclosure of Personal Information in certain circumstances where there is a concern for health and safety, or in an emergency.
A User may withdraw their consent to allow Sentrex to collect Personal Information and/or Personal Health Information, however, Sentrex will still be required to maintain certain records with regard to the distribution of medication to comply with provision laws.
If a User withdraws or limits its consent for Sentrex to collect or disclosure Personal Information and/or Personal Health Information, Sentrex may be limited in its ability to provide pharmacy services – as this may limit Sentrex’s ability to access essential information, or limit its ability to contact a User’s insurer, physician, guardian, etc.
Importantly, this Website is intended for users who are over 18 years of age. Persons who are 18 years of age or less should not provide any Personal Information or Personal Health Information directly to Sentrex, and Sentrex will require a parent or guardian to communicate directly with Sentrex for all services related to children or minors.
Sentrex collects Users’ Personal Information and Personal Health Information in order to enable us to communicate with Users and provide them with our services. Sentrex collects a User’s Personal Information in one of three ways: unsolicited information provided by a User, information obtained from the public or third parties, and information collected from a User’s computer or other electronic device.
Sentrex may collect unsolicited Personal Information and Personal Health Information provided by a User voluntarily, such as data entered into forms or data fields on the Website or via any other online resources.
Information from Public or Third-Parties
Sentrex may collect Personal Information and Personal Health Information from Users that register on the Website from public or third party information sources to verify their professional credentials and identity. If names and contact information for a User’s physician and other health practitioners are provided via the Website or via any other online resources, Sentrex may contact them to collect further information.
Information Collected from a User’s Computer or other Electronic Device
Sentrex collects information from a User’s computer and other electronic devices when a User accesses the Website and other online resources. The information that is collected during this process includes but is not limited to a User’s Internet Protocol (IP) address, domain name, browser type, date and time of a User’s request and information provided by tracking technologies, such as cookies and single-pixel tags, which are defined below.
If a User is accessing the Website from a mobile device, Sentrex may collect information about the User’s device, such as a User’s device ID and device type, as well as usage information, use of mobile websites and other mobile resources.
“Single-pixel tags,” also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible. Single-pixel tags are used to collect information in web logs that do not identify a User personally such as web pages viewed, the website a User came from and the advertisement the User clicked on to visit the Website. Single-pixel tags are also used to confirm whether promotional or other commercial e-mail messages that are sent via the Website are opened.
In order to properly manage the Website, Sentrex may also anonymously use log information on operational systems, and identify categories of Users by items such as domains and browser types. Statistics may be reported to a party assisting Sentrex in offering the Website, such as webmasters.
Sentrex only collects Personal Information and Personal Health Information to the extent that it is necessary to accomplish the specific purposes for which it is being collected.
Sentrex collects, uses and discloses Personal Information to better understand a User’s needs and to provide a User with better services. In particular, Personal Information and Personal Health Information is collected for the following reasons:
Sentrex may remove identifying data from your Personal Information and Personal Health Information to be used to assess various factors, including trends in prescriptions, compliance, and health, in order to improve upon our services. Personal Information and Personal Health Information from which identifying data has been removed may be shared with third parties for the purposes set out above.
In certain limited circumstances, Sentrex may be required to release or provide access to Personal Information or Personal Health Information in response to a subpoena, search warrant, court order, law, or regulation. In such case, Sentrex will take all appropriate measures to ensure that Users’ Personal Information and Personal Health Information is protected to the greatest extent possible while Sentrex cooperates fully with court and law enforcement authorities in this regard.
Users specifically consent to Sentrex, or Permitted Third Parties (as defined below), using Personal Information and Personal Health Information as follows:
sharing a User’s contact details and any reviews or assessments of that User’s performance of or interaction with health services or products for the purpose of contacting individuals with a view to entering into agreements with Sentrex for the provision to them of services similar to the services being provided by Sentrex.
Sentrex allows Users to request the filling of prescriptions and refills directly to patients or medical clinics. In order to complete this process, Sentrex will collect, use and transmit Personal Information and Personal Health Information across computer systems and networks. By submitting the prescription information and other Personal Information and Personal Health Information, our representatives, pharmacists and pharmacy technicians will have access to your Personal Information.
In order to properly provide Users with pharmacy services, Sentrex may need to contact:
Your Personal Information may be disclosed to the above-mentioned persons to the extent required to properly and safely provide pharmacy services.
Users specifically consent to Sentrex disclosing Personal Information and Personal Health Information to Permitted Third Parties (strictly in accordance with the terms of this Electronic Privacy Agreement) to inform such external individuals and organizations, where necessary, of possible adverse events, product complaints, special situation reports or medical inquiries, or to assist such Permitted Third Parties in investigating, responding to, remedying, or preventing future adverse events or complaints.
Sentrex may communicate with and disclose your Personal Information or Personal Health Information to persons who Users expressly designate to be involved in their health care or health care decisions, such as a physician, guardian or attorney.
Users understand that Sentrex may disclose Personal Information or Personal Health Information to Permitted Third Parties (strictly in accordance with the terms of this Electronic Privacy Agreement) which may be located, or have affiliates or resources located, in countries outside of Canada whose laws provide for less protection for Personal Information, and Users specifically consent to their Personal Information being transmitted to any such countries. For certainty, nothing in this paragraph shall allow Sentrex to disclose Personal Information to Permitted Third Parties unless such disclosure is governed by agreements that require Personal Information and Personal Health Information to be protected appropriately.
Users understand that Sentrex may notify Permitted Third Parties if Sentrex becomes aware of any non-compliance with any privacy laws, including any unauthorized or unlawful collection, use or disclosure of or any accidental loss or destruction of, or damage to Personal Information or Personal Health Information or of any circumstances that would cause a reasonable data security professional to suspect that such collection, use or disclosure, loss, destruction, damage or non-compliance had occurred or will occur.
A User may withdraw their consent to Sentrex’s collection, use and disclosure of Personal Information and Personal Health Information at any time, subject to legal and/or contractual restrictions and upon reasonable notice, by contacting Sentrex’s Privacy Officer. Please note certain Personal Information and Personal Health Information will be collected automatically when a User visits the Website. A User’s continued use of the Website will be deemed consent to obtain any Personal Information and Personal Health Information that derives from the User’s use of the Website.
A User may choose not to provide Personal Information to Sentrex by electing not to enter any Personal Information into a form or data field, and by not using any personalized services provided by the Website or by any other online resources. However, some of the Website may only be available to Users that provide Personal Information or request the use of personalized services.
If a User previously agreed to permit the use of Personal Information for marketing or promotional purposes, the User may revoke consent by following the opt-out instructions in each communication or by writing to Sentrex’s Privacy Officer.
Sentrex employs physical, administrative, and technological security safeguards appropriate to the sensitivity of the information. With respect to Personal Health Information collected, Sentrex acts as custodian thereof and takes all precautions required by PHIPA to prevent the unauthorized disclosure thereof.
Users may access, update, and correct Personal Information in the possession of Sentrex, subject to certain exceptions prescribed by law.
Upon written request, Sentrex will provide a User with any Personal Information and Personal Health Information in its possession to the extent required by law.
If a User would like to access any of its Personal Information and Personal Health Information, or believes that any of the Personal Information and Personal Health Information collected by Sentrex relating to a User is incorrect or incomplete, please send an electronic message to Sentrex’s Privacy Officer, as provided below.
To comply with existing federal and provincial legislation, and to ensure that we are able to refer to a User’s Personal Information and Personal Health Information when necessary, Sentrex keeps records of all prescription medications dispensed. Personal Information and Personal Health Information is retained by Sentrex for minimum time periods required by law. When Personal Information and Personal Health Information is no longer required to be maintained, Sentrex will delete it, or remove personal identifying data from such information.
Terms and Conditions of Use of Website
Third Party Links and Web Sites
For More Information
Attn: Privacy Officer
3-250 Shields Court
Markham, ON L3R 9W7
For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Or your provincial office of the Information and Privacy Commissioner for more information.