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Privacy Policy


[Revision No.: 3.0]

Commitment to Privacy

PatientCare Solutions Inc., and its affiliated companies ("PatientCare" or the "Company"), among other things, are in the business of delivering services relating to the establishment, operation and management of various patient support programs ("Program" or "Programs"). Such Programs may be in connection with certain medications and/or medical treatments prescribed to individuals by health care practitioners and may be sponsored by third parties such as pharmaceutical and retail pharmacy organizations. The Programs are offered on a voluntary basis and typically provide enrolled patients and/or their health care practitioners with health, nutrition, lifestyle, disease and condition specific education and other health related support services.

PatientCare is committed to protecting the privacy and security of Personal Information (as the term is defined below) provided to or collected by PatientCare in connection with its operations, including the Programs. This Privacy Policy ("Policy") explains PatientCare's Personal Information handling practices.


Application

This Policy applies to the Personal Information of individuals which are provided to or collected by PatientCare in connection with its operations and Programs; and include the Personal Information of PatientCare's web-site users and applicants who seek employment (including professional engagement) directly with PatientCare ("Individuals" or "Individual").

PatientCare's web-site may contain links to third party web-sites that are not governed by this Policy. Although PatientCare endeavors to only link to web-sites with high privacy standards, this Policy does not apply once you leave PatientCare's web-site. Additionally, PatientCare is not responsible for the privacy procedures employed by such third party web-sites. Therefore, it is suggested that users of PatientCare's web-site review the privacy policies of third party web-sites to learn how users' Personal Information may be collected, used and disclosed (sometimes also referred herein collectively as "Handling" or "Handle").


PERSONAL INFORMATION HANDLING PRACTICES


Overview

PatientCare takes responsibility for Individuals' Personal Information under its care and/or control and has designated personnel as its Privacy Officer (contact information provided below) who is accountable for PatientCare's compliance with this Policy. Upon request, PatientCare will make readily available to Individuals specific information about its policies and procedures relating to the Handling of Personal Information. If you have any questions relating to the Handling of Personal Information by PatientCare and/or this Policy, please contact PatientCare's Privacy Officer at:

Privacy Officer
3190 Harvester Road, Suite 203
Burlington, Ontario  L7N 3T1

Tel.: 905-633-8683 ext. 302
Fax: 905-633-8094
Email: privacy.officer@patientcaresolutions.com


Accountability

PatientCare has implemented policies and procedures to give effect to this Policy, including training and communicating to its employees about this Policy and the Company's processes relating to the Handling of Individuals' Personal Information. PatientCare transfers Personal Information to trusted third-parties who provide services to PatientCare, such as data processing / storing and Program web-site hosting. This may require that Personal Information be transferred across provincial and national borders, in which case, the Personal Information may become subject to the legislation of that jurisdiction to which it has been transferred. PatientCare will only transfer Personal Information to third parties who have executed contracts requiring them to protect the privacy and confidentiality of the Personal Information provided to them for purposes of performing their functions for PatientCare.


Collection

Prior to or at the time Personal Information is collected, PatientCare will identify the purposes for which such information is being collected. PatientCare will limit the collection of Personal Information to that which is reasonably required for the purposes described to the Individual providing such information and/or as described in this Policy.

PatientCare collects Personal Information only for the administration of its day-to-day operations and Programs, which includes the following:

PatientCare collects Personal Information only for the purposes identified to Individuals and as set forth in this Policy. PatientCare shall only collect Personal Information by fair and lawful means.

Individuals provide PatientCare their Personal Information voluntarily. Individuals may choose whether or not to provide PatientCare their Personal Information; however, without certain Personal Information, PatientCare may not be able to enroll an Individual into a Program or consider an Individual for employment with PatientCare.

PatientCare may collect usage pattern information from users of the Company's web-site. In this regard, PatientCare may use "Clickstreaming" or other similar technologies to track the paths of online visitors as they access the Company's web-site.

PatientCare will not routinely update Individuals' Personal Information unless such a process is necessary to fulfill the purposes for which the information was collected.


Consent

In the majority of cases, PatientCare obtains express consents directly from Individuals to Handle their Personal Information, i.e.: when an Individuals register for Programs with PatientCare.

PatientCare obtains the following forms of consents from Individuals:

PatientCare will only require Individuals to consent to the Handling of their Personal Information as a condition to the supply of services if such Handling is not necessary to fulfill the identified purposes.

Individuals may modify or withdrawal their consents at any time upon reasonable notice to PatientCare, subject to legal and contractual restrictions. If an Individual withdraws his or her consent from PatientCare to use and/or disclose the Individual's Personal Information, such Individual may not be able to participate in the Programs offered by PatientCare.

Consent may be withdrawn or modified by contacting PatientCare at the contact information provided in this Policy. Please be advised that it may take up to 30 days to complete such request. Prior to the changes taking effect, Individuals may still be contacted due to the Program and/or marketing efforts that commenced prior to the modification of their consents.

Except to the extent required or permitted by law, when PatientCare uses or discloses Individual's Personal Information for a purpose not previously identified, PatientCare will reasonably identify and obtain consent for the new purpose prior to it using or disclosing such Personal Information.


Use of Personal Information

PatientCare restricts the use of Personal Information to the purposes identified in this Policy and for which PatientCare has obtained explicit or implicit consent from the Individual. In accordance with established industry practices, industry standards and applicable legislation, PatientCare retains Personal Information for only as long as necessary to fulfill the identified purpose.

In accordance with established industry practices and standards, PatientCare will destroy, erase or make unidentifiable any Personal Information that is no longer required for the identified purpose.


Disclosure to Third Parties

PatientCare may disclose limited Personal Information with trusted third party organizations so that they may offer goods and services that may be of interest to Individuals. Individuals may modify or withdraw their consents to any such marketing related activities at any time by contacting PatientCare's Privacy Officer at the contact information set forth in this Policy.

In accordance with applicable legislation, PatientCare discloses Personal Information to third parties only for the purposes identified in this Policy and with the appropriate consent of the Individual. Under some circumstances, PatientCare may be required to disclose certain information to regulatory authorities to comply with law. In these circumstances, only the information specifically requested will be disclosed, and PatientCare will take reasonable measures to ensure that such authorities are entitled to receive the requested Personal Information.

There are circumstances where the use and/or disclosure of Personal Information may be justified or permitted without the consent of the Individual. Such circumstances may include:


Access to Personal Information

PatientCare provides Individuals with access to their Personal Information for review and update. Upon request, PatientCare will inform an Individual of the existence, use and disclosure of his or her Personal Information and shall give access to that information. An Individual may challenge the accuracy of the Personal Information in PatientCare's care and control, provided that the Individual can reasonable demonstrate the inaccuracy of such information.

An Individual may access his or her Personal Information by writing to PatientCare's Privacy Officer at the contact information provided in this Policy. Access to Personal Information shall be provided in accordance with PatientCare's established policies and procedures.

Normally, there is no cost for reasonable access to Personal Information. PatientCare shall advise Individuals of the cost, if any, prior to providing access to the Personal Information. In order to provide access to Personal Information, PatientCare may require additional forms of information, including other Personal Information to validate the requester's entitlement to the requested Personal Information. Such other Personal Information collected will only be used to process the access request.

PatientCare will assist any Individual who needs help in preparing an access request to his or her Personal Information in the care and control of PatientCare. For example, if the requester has a sensory disability and upon request, PatientCare will provide access to the Personal Information in an alternative format.

PatientCare will provide a response within 30 days of receiving an access request to Personal Information. If PatientCare is unable to provide the requested access to Personal Information, PatientCare will explain the reasons and any recourse available to the Individual. For example, if PatientCare is unable to separate the requester's Personal Information from that of others, PatientCare will not be able to provide access to such information.

Where Personal Information has been used to make a decision about an Individual, PatientCare shall retain the Personal Information for a period of time that is reasonably sufficient to allow such individual to access his or her Personal Information.

PatientCare has procedures in place to address privacy related issues. In this regard, Individuals may address privacy related issues in writing by contacting PatientCare's Privacy Officer who is accountable for PatientCare's compliance with this Policy. In this event, PatientCare's Privacy Officer will work with such Individuals in an effort to resolve any privacy related concerns they may have.

PatientCare takes privacy matters very seriously. As such, PatientCare shall respond to every privacy related enquiry or complaint within a reasonable amount of time, but not exceeding thirty (30) days. In the event of a privacy related complaint, PatientCare shall acknowledge, record and investigate the substance of the privacy complaint. If a complaint is found to be justified, appropriate measures will be taken, including but not limited to, amending this Policy.


Safeguards

PatientCare protects Personal Information against unauthorized access. In accordance with established industry practices and standards, PatientCare has security measures in place to protect Personal Information. Personal Information shall be protected by security measures appropriate to the sensitivity of the information.

PatientCare's security measures include:

Individuals are reminded to take reasonable measures to protect themselves against unintended access to their Personal Information. For example, Individuals should only disclose Personal Information to organizations they trust.


Privacy Assistance

PatientCare updates this Policy accordingly to ensure it reflects PatientCare's most current Personal Information Handling practices. Given this, Individuals are encouraged to review this Policy on a regular basis by visiting http://www.patientcaresolutions.com/legal/privacy/.

PatientCare is committed to upholding this Policy. If you have any questions about PatientCare's Personal Information Handling practices that have not been answered in this Policy, please contact PatientCare's Privacy Officer at the contact information provided in this Policy.


Regulatory Authorities

The regulatory authorities that oversee PatientCare's Handling of Individuals' Personal Information are the Office of the Privacy Commissioner of Canada and the Office of the Information and Privacy Commissioner of Ontario.