Privacy Policy

“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).

Since January 1, 2004, all Canadian organizations engaged in commercial activities have been required to comply with the PIPEDA and the Canadian Standards Association Model Code for the Protection of Personal Information, incorporated by reference into PIPEDA. These obligations extend to Sentrex and are integrated into the Privacy Policy herein.

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.

By using the Website, the User consents to the collection, use, and disclosure of the User’s Personal Information in accordance with this Electronic Privacy Policy. If the User does not consent to the Privacy Policy, as set out herein, the User must immediately cease use of the Website. Please note that the User’s access and continued use of the Website will be deemed as consent by Sentrex.

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.

Unsolicited Information

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.

“Cookies” are small text files placed on a User’s hard drive that assist Sentrex in providing a customized browsing experience. Cookies contain a unique identification number that identifies a User’s browser, but not the visitor, to Sentrex’s computers each time a User visits the Website. Sentrex uses cookies to make navigation of the Website easier for visitors and to facilitate efficient registration procedures. If a User is concerned about cookies, most browsers permit Users to refuse to accept all cookies or to notify Users when a User has received a cookie. However, a User should note that if the User refuses to accept cookies, the User may not be able to use some of the features available on the Website and other online 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:

• internal record keeping, including keeping record of medications dispensed, to comply with existing federal and provincial legislation;
• to identify products, facilitate orders and otherwise provide Sentrex’s services;
• to ensure that Users are not given medication that is not appropriate;
• to improve services;
• in order to receive payment from Users and from their health plan providers;
• to co-ordinate care with other pharmacies and health care providers
• to register a User for, and facilitate a User’s participation in, certain areas of the Website;
• to provide information and reminders to Users regarding their prescriptions;
• to tell Users about health-related benefits or services that may be of interest;
• to gather a User’s opinion and feedback;
• to audit online resources for authorized access and security;
• to submit reports to Health Canada;
• to contact a User’s pharmacist or prescribing physician to discuss prescription-related information and concerns;
• to communicate with individuals involved in your care or the payment of your care;
• to customize the Website according to a User’s interests;
• to address possible adverse events, product complaints, special situation reports or medical inquiries;
• for purposes related to the filing and/or prosecution of any regulatory applications, including new drug and/or patent applications; and
• such other uses as may be permitted or required by applicable law.

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:

• combining information relating to the User with other information linked to that User, for example any reviews or assessments by or of that User’s performance of or interaction with the health services or products, and any information received from third parties such as recruitment agencies;
• disclosing information as required by any applicable government laws or regulations, and to financial institutions or governmental authorities; and
• 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:

• health insurance providers (if applicable) to assess coverages and benefits;
• doctors or other medical professionals to discuss a User’s medical background and prescription requests; and/or
• such other persons as may be required in order to fulfill a prescription request.

Your Personal Information may be disclosed to the above-mentioned persons to the extent required to properly and safely provide pharmacy services.

Personal Information and Personal Health Information will be accessible to Sentrex, and to individuals and organizations that use Personal Information and Personal Health Information gathered by Sentrex such as vendors, suppliers and strategic partners (“Permitted Third Parties”), solely for and at the direction of Sentrex. Uses and disclosures of Personal Information and Personal Health Information by Permitted Third Parties are governed by agreements that require Personal Information and Personal Health Information to be protected appropriately. When Sentrex allows a third-party service provider to have access to your Personal Information, they will only be permitted to take it or use it for purposes that are consistent with this Privacy Policy. Sentrex’s ability to allow others to access Personal Health Information is further restricted by PHIPA.

Users specifically consent to Sentrex disclosing Personal Information and Personal Health Information to Permitted Third Parties (strictly in accordance with the terms of this Privacy Policy) 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.

Unless otherwise advised, Sentrex will not share Personal Information or Personal Health Information except as described in the Privacy Policy and other applicable privacy notices. However, Sentrex reserves the right to disclose Personal Information and Personal Health Information, including e-mail addresses, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by law. Except as provided in the Privacy Policy, Personal Information and Personal Health Information will not otherwise be shared without a User’s permission.

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 Privacy Policy) 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.

Sentrex may disclose your Personal Information or Personal Health Information to a buyer or transferee in connection with the sale, assignment, or reorganization of its business, in which case Sentrex will require any such buyer to agree to treat it in accordance with the terms of this Privacy Policy.

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.

Sentrex will take all reasonable and legally required steps to protect Personal Information and Personal Health Information as it is transmitted from a User’s computer to the Website or other online resources and servers. Sentrex will also protect Personal Information and Personal Health Information from unauthorized access, disclosure, alteration or destruction. Sentrex ensures that all affiliates and other third parties that are retained to perform services on Sentrex’s behalf and are provided with Personal Information and/or Personal Health Information are contractually required to observe the Privacy Policy. It is a User’s personal responsibility to secure a User’s own copies of any logins, passwords and related access codes used on or for the Website.

Please note, security risks on the Internet cannot be eliminated, and Sentrex cannot and does not guarantee that a User’s Personal Information and Personal Health Information will not be accessed in ways not otherwise described in the Privacy Policy.

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.

Former Users

If a User ceases using the Website, or a User’s access to the Website has been terminated, Sentrex may continue to use and disclose a User’s Personal Information and Personal Health Information in accordance with the Privacy Policy.

Terms and Conditions of Use of Website

Any applicable terms and conditions of use governing a User’s use of the Website contain important provisions, including provisions disclaiming, limiting, or excluding the liability of Sentrex for a User’s use of the Sentrex Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding a User’s use of the Sentrex Website. Each of those provisions applies to any disputes that may arise in relation to the Privacy Policy, including any collection, use and disclosure of Personal Information and Personal Health Information and are of the same force and effect as if they had been reproduced directly in this Privacy Policy.

Third Party Links and Web Sites

The Website may contain links to other third-party websites or Internet resources, which are not affiliated with the Website, nor provided by Sentrex, and are not subject to the Privacy Policy. The User assumes any risk associated with any third-party links or websites. Sentrex assumes no responsibility or liability for, or control over any third-party websites or their collection, use and disclosure of a User’s Personal Information and/or Personal Health Information.

Privacy Policy Amendments

To accommodate amendments to the Website, changing technology, and legal developments, the Privacy Policy may be revised in Sentrex’s absolute discretion and without any prior notice or liability to the User or any other person. Sentrex’s collection, use and disclosure of the Personal Information and Personal Health Information through the Website will be governed by the version of the Privacy Policy in effect at that time when the information is collected, used, or disclosed. New versions of the Privacy Policy will be posted on the Website and will be available upon request from Sentrex. A User’s continued access, use and/or dealings with the Website after any amendments to the Privacy Policy, will signify a User’s consent or continued consent to the collection, use and disclosure of Personal Information and Personal Health Information in accordance with the revised Privacy Policy. 

For More Information

For more information about the Privacy Policy, please contact the Sentrex Privacy Officer, Gillian Dinning, via electronic mail at privacy@sentrex.com, or write to us at:

Attn: Privacy Officer
Sentrex Pharmacy
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
30 Victoria Street
Gatineau, Quebec
K1A 1H3

Or your provincial office of the Information and Privacy Commissioner for more information.