DrugFinder Terms of Service

Reformulary DrugFinder® Privacy Policy
Last Updated: July 28, 2018

Introduction

Reformulary Group Inc. (“Reformulary Group”, “we” or “us”, and terms of similar meaning) provides the Reformulary Drug Finder® service (“DrugFinder”), available through a website browser, a mobile device browser, downloadable application, or other technology used to access any features, functionality, content or information (collectively hereinafter referred to as the “Site”), and the services provided by or through the Site (the “Services”). At Reformulary Group we are committed to your privacy. This means we do not transfer, distribute, disclose, rent or sell any of your personal information to third parties except as provided for in this policy (the “DrugFinder Privacy Policy”) or as specifically consented by you.

Reformulary Group has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws. By accepting this Privacy Policy in registration or by visiting and using our Site and/or utilizing the Services, you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Service (“Terms of Service”).

Scope

This Privacy Policy applies to all personal information (“Personal Information”) collected, used or disclosed by Reformulary Group from our clients, and their representatives whom they give user access to their account, as well as our customers’ employees who may access the Services (collectively “Users”).

Accountability

Reformulary Group is responsible for the Personal Information under our possession and control. We have designated a Chief Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.
Information We Collect

a. Personal Information

Personal information is any information recorded in any form that identifies or can identify an individual and includes any information provided to us by Users in using our Site and Services.

At various points on the Site, you might choose to actively provide certain kinds of information, including personal information, such as your full name and e-mail address and other personal details, as well as personal health information, such as information regarding your prescription drugs and pharmacy information, including drugs dispensed, dosage and other prescription information. All information that you provide on the Site and in using the Service is provided at your option in connection with your use of the Site when you use interactive tools that may be available on the Site.

In any case, by submitting information via an "active information collection point" on the Site, you are expressly consenting to the collection, use, and disclosure of such information in accordance with the Privacy Policy. "Active information collection points" on the Site may include:

1. DrugFinder® Medicine Cabinet

By utilizing this feature of the Site and Services, you may provide Reformulary Group with information about the prescription drugs that you take and/or are prescribed, including drugs dispensed, pharmacy information, dosage and frequency.

2. E-mail Reply Mechanisms

The Site 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 all 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.

3. Saved Search

By utilizing this feature, you can create saved searches of the prescription drugs you may be interested in for future visits to Site. Through this feature, Reformulary Group will collect information regarding the types of prescription drugs that you have decided to add to your saved search list.

4. Question, Comment, and Feedback Forms

The Site may post a form for you to use in submitting questions, comments, and other feedback about Reformulary Group, its services and other topics. Reformulary Group uses such feedback information to improve the Site, 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 personally identifiable information, such as your name and e-mail address, so that Reformulary Group may respond to your inquiry.

b. Non-Personally Identifiable Information

Personal information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any User. This may include information related to prescription drug usage aggregated among many Users, such as top searched drugs and top drugs saved in medicine cabinet. Such information by itself or together cannot be tracked to a specific individual’s personally identifiable information.

  • How do we use Personal Information?
  • Reformulary Group collects Personal Information for the following purposes:
  • to provide Services to our Users;
  • to establish and maintain responsible commercial relations and to communicate with you in order to provide service. This includes, but is not limited to, communications relating to billing, advertising, promotion and account verification;
  • to respond to any correspondence you may direct to us;
  • to understand, research, and improve our Services;
  • for customer and User needs and preferences;
  • to send notifications to you about prescription drugs;
  • to send Users notifications about prescription drugs and other relevant medical information;
  • to direct advertisements to you about our company, DrugFinder and our products and services that may be of interest to you;
  • to enforce our Terms of Service and other service agreements;
  • to provide you with system or administrative messages;
  • to meet legal and regulatory requirements; and
  • for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied.
How do we use Non-Personally Identifiable Information?

The Site 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 Site to collect a range of non-personally identifiable 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 Web, the specific pages you visit on the Web Site, and the address of the Web site you visited before coming to the Web Site. In addition, Reformulary Group may aggregate personal information among our Users, including demographic and prescription drug related information.

Reformulary Group can use such non-personally identifiable information for a variety of purposes, such as to administer the Site, customize the Site to your preferences, and compile aggregated statistics for marketing and research purposes. Reformulary Group reserves the unrestricted right to use this passively collected, non-personally identifiable information, including to: analyze trends; track movements around the Site; and permit access to, or otherwise transfer it to Reformulary Group’s affiliates, or business partners (“Affiliates”).

This research can be used to provide our customers and Affiliates with statistics and metrics that may be of interest to them (for example statistical data related to programs). This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered and treated as Non-Personally Identifiable Information under this Privacy Policy.

Consent

We respect your privacy and, unless otherwise required by law, we will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing us Personal Information to register for our Services is implied consent to use such information to provide you the associated services.

Where appropriate, Reformulary Group will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Reformulary Group wants to use information for a purpose other than those identified above). In obtaining consent, Reformulary Group will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by Reformulary Group may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Reformulary Group shall take into account the sensitivity of the Personal Information and the reasonable expectations of our customers and Users. Reformulary Group will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide you with the Services and accordingly losing access to the Site. In order to withdraw consent, you must provide notice to Reformulary Group in writing.

Limiting Use, Disclosure and Retention

Unless required by law, or in connection with a business transaction, Reformulary Group shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining your consent, where such consent may not reasonably be implied.

As noted above, Reformulary Group does not disclose your Personal Information to third parties. Notwithstanding, your Personal Information may be transferred to our affiliates and third-party suppliers and contractors, including third-party suppliers, contractors and agents who are contracted by Reformulary Group to assist it in providing and developing products and services, for example, customer service and user support and research and development. Such Affiliates will only use your Personal Information for the purposes identified in this Privacy Policy. Such Affiliates may be located outside of Canada, including in the United States, and your Personal Information may be collected, used, disclosed, stored and processed in such jurisdictions for the purposes described in this Privacy Policy.

Reformulary Group takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such parties. If your Personal Information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

In the event your Personal Information is disclosed to a third party pursuant to a business transaction (including a potential sale or financing), Reformulary Group will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only Reformulary Group’s and our affiliates and third-party suppliers and contractor’s employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about our Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of your Personal Information.

Reformulary Group will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Reformulary Group.

Using the Site & Cookies

The "passive information collection" technologies that we use may include “cookies”. Cookies are small text files that store information about your interactions with a particular Web site, 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 Web site by allowing servers to access certain information quickly. "Session" cookies can be used to help a user's browser navigate a Web site more smoothly and may show up if the user comes from a Web site with which the subsequent Web site has some relationship (e.g., a Web site of an affiliated company) and can give helpful information. "Persistent" cookies can be used to customize a Web site 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 Web site.

The Site uses both session/temporary cookies and persistent/permanent cookies to store information that allows Reformulary Group to offer you better service and to navigate through the Site with ease. To make the Site easier to use, Reformulary Group may combine information collected via cookies with personally identifiable information. Note that if you configure your browser to reject cookies, you might not be able to access important functions or areas of the Site or enjoy certain conveniences at the Site.

By continuing to browse the Site and use our Services, you are agreeing to our use of cookies. You can find more information about how to manage cookies for all the commonly used internet browsers by visiting
www.allaboutcookies.org. This website will also explain how you can delete cookies that are already stored on your device.

How can I access my Personal Information?

Upon request, Reformulary Group will provide information to a User regarding the existence, use and disclosure of his or her Personal Information. Reformulary Group will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A User may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, Reformulary Group may not be able to provide access to all the Personal Information it holds about a User. Exceptions may include information that is prohibitively costly to provide, 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. Reformulary Group will provide the reasons for denying access upon request.

Safeguards We take administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and in a controlled environment with limited access. We educate our employees with respect to their obligations to protect your personal information.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our website if you consider that information to be sensitive.

Challenging Compliance

Reformulary Group will maintain procedures for addressing and responding to all inquiries or complaints from Users about Reformulary Group's handling of Personal Information. Reformulary Group shall investigate all complaints. All inquiries or complaints involving Reformulary Group's handling of Personal Information or compliance with this policy or with PIPEDA shall be directed to Reformulary Group's Chief Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Reformulary Group finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact our Privacy Office as follows:

Website:
https://reformulary.com/index_en.php?page=contact_us

Email: privacyofficer@reformulary.com

General

Reformulary Group reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on our Site and will be effective as of the date of posting.