What you should know about our commitment to protecting the confidentiality of your personal information.
Last updated May 7, 2021
What is privacy and why does it matter?
Our commitment to protecting your privacy
How we collect, use and disclose personal information?
We only ask you for the information we need
Why we need the information
We may collect and use personal information to:
We will obtain your permission
We collect, use and disclose your personal information with your permission.
Your permission may be expressed in writing or be implied when you provide us with information verbally, electronically, or through your authorized representative.
You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice, by contacting our Chief Privacy Officer at (416) 519-9729 or email@example.com. When you withdraw your permission, some of your access to and use of the Service may be impacted, and we may not be able to offer you access to the Service any longer.
Where medical or health information about you is collected or disclosed, we will obtain your consent prior to doing so. We will not share it, unless your consent has been obtained or we are required to so by law.
Before we make personal information available to third parties, other than an authorized employee, agent or service provider who needs it, or except as required by law or where Reformulary Group reasonably believes it is necessary to do so to comply with the law, we will tell you at the time we obtain your consent or before we make the information available, who those persons or organizations are, the kind of information we want to share with them and why.
We will limit how long we keep information
We will keep your personal information only as long as it is necessary for the purposes for which it was collected, or as required by law.
When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.
We will protect your personal information
We are responsible for your personal information
We are responsible for all personal information in our possession so that we can provide you with the Service. We store and process all your personal information within Canada.
How we protect information
Access to your personal information is restricted to our employees, authorized service providers and partners who need it to do their jobs.
We have developed and are continuing to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We will maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures such as security clearances and limiting access on a "need-to-know" basis, and technological measures such as the use of passwords and encryption. While we endeavor to protect all information, the most sensitive information, such as health information, receives the highest level of protection.
Notwithstanding these measures, no collection, storage or transmission of information over the Internet on websites or otherwise can be guaranteed to be 100% secure, and therefore we cannot ensure, warrant or guarantee that there will be no unauthorized access, hacking, data loss or breaches of our security safeguards. Accordingly, you should not transmit personal information to us over the Internet if you consider that information to be sensitive.
If you suspect that the personal information you provided to us has been improperly accessed or used, please contact our Chief Privacy Officer at (416) 519-9729 or firstname.lastname@example.org.
Your right to access your personal information
You have the right to ask whether we hold any personal information about you and to see that information, as provided by law.
You also have the right to know:
To access your personal information, please contact our Chief Privacy Officer as set out below and we will assist you. You may be required to put your request in writing to confirm your request and identity.
Under certain circumstances, it is possible that we may not be able to provide you with all of the information you may have requested. For instance, we may not be able to provide you information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Fees may also be applied to any copy of the requested personal information. We may decide to provide you access to your personal health information through a health practitioner.
If you believe we have not dealt with your request to your satisfaction, you can submit a complaint to us to resolve your privacy-related issue.
How to request an update or correction
If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it.
If you show that your personal information is inaccurate or incomplete, we will take all reasonable measures to make the necessary changes.
If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures.
Personal Information and Online Security
When you visit the Website you are anonymous unless you voluntarily choose to identify yourself. You are not required to provide personal information to use our Website unless a feature requires it. If a feature does require providing personal information, in these specific cases, we have physical, electronic and procedural safeguards in place to help protect your online personal information from unauthorized use or improper access.
Although we have physical, electronic and procedural safeguards that are commercially and reasonably adequate to protect personal information, any such systems may be subject to human and operational error or inadvertent access. In particular, because the Internet is an open system, we cannot and do not guarantee that personal information entered by you online will not be misappropriated, intercepted, modified, deleted or used by others.
Online Data Collection Tools: Improving And Evaluating Website Functionality and Effectiveness
Like many organizations, Reformulary Group may from time to time gather data regarding how visitors explore our Website - information about the number of new and repeat visitors, where on the Website a visitor explores, how long they visit, and similar details. All such information is collected in an aggregate form and is used to improve our Website performance and functionality, create a better experience for our visitors, analyze trends, track movements around the Website, generate aggregate reports and measure the response to web marketing campaigns.
Passive Information Collection
The Website uses various technologies to passively collect information from you while you are visiting (that is, you do not actively provide this information). Such technologies allow the Website to collect a range of non-personal information, including your Internet Protocol (IP) address (a unique identifier automatically assigned to your computer when logging onto the Internet), the type of web browser and operating system you use, the date and time you visit the Website, the specific pages you visit on the Website, and the address of the website you visited before coming to the Website.
Reformulary Group can use such passively collected information for a variety of purposes, such as to administer the Website, customize the Website to your preferences, and compile aggregated statistics for marketing and research purposes. Reformulary Group reserves the unrestricted right to use this passively collected, non-personal information, including to: analyze trends; track movements around the Website; generate aggregate reports; and permit access to, or otherwise transfer it to Reformulary Group’s affiliates, or business partners.
The “passive information collection” technologies that we use may include “cookies” and “pixels”. Cookies are small text files that store information about your interactions with a particular website, either temporarily (known as a "temporary" or "session" cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a "permanent" or "persistent cookie"). Cookies can make it easier to use a website by allowing servers to access certain information quickly. "Session" cookies can be used to help a user's browser navigate a website more smoothly and may show up if the user comes from a website with which the subsequent website has some relationship (e.g., a website of an affiliated company) and can give helpful information. "Persistent" cookies can be used to customize a website for a user, such as by storing passwords, preferences, and registration and account information so that users do not have to reenter them each time they visit a website.
This Website uses both session/temporary cookies and persistent/permanent cookies to store information that allows us to offer you better service and to navigate through the Website with ease. To make this Website easier to use, we may combine information collected via cookies with personal information. Note that if you configure your browser to reject cookies, you might not be able to access important functions or areas of the Website or enjoy certain conveniences at the Website.
Active Information Collection
At various points on the Website, you might choose to actively provide certain kinds of information, including personal information, such as your full name, e-mail address, date of birth and other personal information (including personal health information), such as information regarding your health symptoms, conditions, prescription drugs and pharmacy information, including drugs dispensed, dosage and other prescription information. For instance, you have the option to create a personal account by completing the registration process on the Website to access additional features of our Service, such as tools to track the impact of medical cannabis on your health and your day-to-day life. You may also complete surveys conducted by third parties on our behalf.
All information that you provide on the Website and in using the Service is provided at your option in connection with your use of the Website when you use interactive tools that may be available on the Website. You should exercise discretion when sharing your personal information, and should not disclose sensitive or confidential information that you wish to remain private.
E-Mail Reply Mechanisms
The Website may provide you with one or more e-mail mechanisms through which you may submit questions or comments. Information you provide via such e-mail mechanisms is optional. Reformulary Group may use the information you provide in your e-mail to respond to your inquiry, and Reformulary Group reserves the right to retain whatever information you submit in your e-mail, including your name, e-mail address, and any comments or other information that you send via the e-mail mechanism.
Question, Comment, and Feedback Forms
The Website may post a form for you to use in submitting questions, comments, and other feedback about Reformulary Group, its Service and other topics. Reformulary Group uses such feedback information to improve the Website, as well as for marketing and research purposes. Most information you provide in such forms is optional, but you will need to provide at least some personal information, such as your name and e-mail address, so that we may respond to your inquiry.
Aggregated and Anonymized Information
Collection of Personal Information From Minors
The Website and our Service is not directed at minors. We do not knowingly collect information from minors under the age of 18 or relevant age of majority or cannabis use in your province or territory of residence.
Your continued access to or use of the Website constitutes your consent to the contents of any updated policy.
How to register complaints
You may register a privacy-related complaint by contacting our Chief Privacy Officer. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right, including changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.
For more information
Principle 1 – Accountability
Each employee of Reformulary Group is responsible for personal information under his or her control and is accountable for compliance with this Code.
Principle 2 - Identifying Purposes
The purposes for which personal information is collected shall be identified before or at the time the information is collected.
Principle 3 - Consent
The prior knowledge and permission of the individual or organization are required for the collection, use or disclosure of personal information, except for legal or security reasons.
Principle 4 - Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.
Principle 5 - Limiting Use, Disclosure And Retention
Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual or organization, or as permitted or required by law.
Principle 6 - Accuracy
Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.
Principle 7 - Safeguarding Information
Personal information will be protected by safeguards appropriate to the sensitivity of the information.
Principle 8 - Openness
Reformulary Group will make readily available to their customers specific information about our policies and procedures relating to the management of their personal information.
Principle 9 - Individual Access
Upon request, an individual or organization will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it. An individual or organization will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 - Handling Customer Complaints And Suggestions
Individuals can address any complaint regarding compliance with the above principles with our Chief Privacy Officer at (416) 519-9729 or at email@example.com.