Pharmacie Michael Assaraf, Pharmacien Inc., a pharmacy affiliated with Sanavie (”Sanavie,” “we,“ “us,” and “our”) is committed to protecting the privacy of personal information in our care and control. This Privacy Policy describes our practices for collecting, using and disclosing personal information collected in the course of providing our personalized patient services (the “Services”) in any manner, including in person, by telephone, by videoconference or via our website located at sanavie.ca (the ”Website”). Please note that pharmacists are solely responsible for pharmaceutical services provided in the course of pharmacy practice.

As part of our Services, we collect certain personal information directly from you, unless we have your consent or are legally permitted to collect your personal information indirectly. We limit the personal information we collect to that which is necessary to serve you.

Collection by Sanavie. We collect your personal information from the Website with your consent. For example, depending on how you use our Services, we will collect:

• Your first and last name
• Your email address
• Your telephone number
• Your home address
• Your private insurance policy number
• Your health insurance number (RAMQ)
• Your payment information
• Connection cookie (see below)
• Medical and pharmacological information required for Services
• Names and contact details of resource persons and informal caregivers

We record your telephone calls and collect any personal information you provide during these calls.

How we use it. We use the personal information we collect to provide our Services. This includes:

Services: Provide the services you request and any necessary support, and evaluate the quality of our services in order to improve them. In particular, our healthcare professionals may use personal information for the specific purpose of monitoring treatment effectiveness and managing potential complications;

Patient records: We use personal information to share patient records between the various parties involved via a technological platform. This enables us, in particular, to identify the patient, relevant data from laboratory tests, and a global overview of the patient’s pharmacological profile and habits;

References: Pharmacists practicing in Québec must, considering their abilities, limitations, available resources, and the best interest of their patient, consult another pharmacist or refer a patient to another pharmacist if the patient’s interest requires it. Accordingly, a community pharmacist or other healthcare professional may contact us regarding a patient requiring specialized treatment. They must obtain the patient’s consent to share information with Sanavie. Client record information, prescriptions and referral forms are sent by fax. Depersonalized communications are sent via email. Once the form and prescription have been received, Sanavie contacts the patient to obtain more personal information about their profile and habits (such as pill organizer use, treatment compliance, etc.);

Delivery: Sanavie ensures delivery of medications to patients, which requires information such as the patient’s first and last name, telephone number and address in order to identify orders;

Telephone assistance: Our telephone assistance service may require the use of personal information to identify a patient;

Personalized claims assistance service: Sanavie may use personal information to complete claims forms to process patients’ claims with insurance companies and the RAMQ;

Research or studies : Patients must give their consent to participate in a study. Potentially eligible patients are identified from the pharmaceutical database and will receive a telephone call from a pharmacist. A description of the research project is provided and consent is sought for the use of information contained in patients’ pharmaceutical records for research purposes.

Obligations : We use personal information to meet our regulatory and other legal obligations.

If we process your personal information with your consent, you have the right to refuse or withdraw your consent by contacting us as described in the “Contact” section below, subject to applicable contractual and legal restrictions. However, please note that if you refuse or withdraw your consent to certain processing of your personal information, we may not be able to provide you with certain Services.

Insurers: Sanavie may share personal information necessary to facilitate reimbursements with insurance companies and RAMQ at the patient’s request or with the patient’s consent.

Other healthcare professionals: Sanavie may share personal information necessary to harmonize medication records with a patient’s community pharmacist at the patient’s request or with the patient’s consent.

Service providers: We may transfer personal information to service providers, pursuant to a written agreement, such as hosting and data processing and analysis, marketing, information technology services and payment processing. Your personal information is stored and processed in Québec. For more information on how our service providers handle personal information, please contact us as indicated in the “Contact” section below.

Research: We also collect, use and disclose aggregated data, such as statistical or demographic data, for various purposes such as studies or research projects.

Business transactions: We may disclose personal information to third parties in connection with a business transaction, such as a sale, financing or other transfer of all or part of our business or assets, for the purposes of evaluating and/or completing the transaction.

Other: We may need to disclose personal information to meet our legal and regulatory obligations, or to comply with the law. We may disclose personal information if we have reasonable grounds to believe that there is a serious risk of death or injury, or in the event of an investigation by the authorities (for example, the Director of Criminal and Penal Prosecutions or a police authority). We may also do so to protect our rights and the health and safety of our employees, as well as to enforce our agreements and recover amounts owed to us.

Your personal information is stored on our systems or those of our service providers, such as Microsoft Azure servers. We also use a platform that facilitates the access and transfer of necessary information to the Québec government’s Health Record and the RAMQ. We retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected, or as long as necessary to comply with our legal and ethical obligations. Subject to any retention periods required by law, Sanavie uses appropriate means to destroy personal information once the purposes for which it was collected or used have been fulfilled.

We take measures to ensure that your personal information is up-to-date and accurate, and to protect it in accordance with its sensitivity level, such as safeguards against unauthorized access, modification, disclosure or destruction. Access to personal information is limited to those employees and service providers who need it to perform their role or function, and each employee is responsible for maintaining the confidentiality of this information. We keep our employees informed of our policies and procedures for protecting personal information. We have implemented appropriate physical, technical, IT and administrative safeguards to prevent a privacy incident from occurring in relation to your personal information. However, as no system or security measure is completely secure, there is a risk that personal information may be lost, stolen or accessed without authorization.

You may request access to or correction of your personal information in our possession or under our control. In certain specific circumstances, you may also have the right to object to the use of your personal information, request its deletion, limit its use, receive a copy of the information you have provided to us for your own use, or file a complaint with a supervisory authority. However, the exercise of these rights is subject to applicable legal restrictions and we may take steps to verify your identity before responding to your request. Should you wish to exercise any of these rights, please contact us in writing using the details given in the “Contact” section below.

The cookies we use include the following types:

Essential cookies : These cookies are essential to the operation and navigation of our Website. They cannot be deactivated. They may be used to ensure the smooth operation of our Website, to enhance the security of our Website, or to comply with our legal obligations.

Analytical cookies: These cookies enable us to observe how you navigate our Website. The information collected by these cookies may include the pages you view, open and exit, as well as the date and time of these actions. It may also include the number of clicks you make, page scrolling and the type of computer system you are using. The search terms you use and the IP address of your device may also be recorded. If you disable these cookies, you may not be able to access certain parts of the Website or take advantage of certain features.

Preference cookies: These cookies improve and personalize the functionality of a Website and the content offered to you based on your choices and previous browsing. Disabling these cookies may restrict access to certain parts of the Website or features. In addition, if you disable cookies, the Website will not be able to retain your preferences from one session to the next, such as your choice of language.

Advertising cookies : These cookies allow us and our advertising partners to create a profile based on your interests by collecting information about your browsing habits. They are used to limit the frequency of the advertisements you see, to evaluate the effectiveness of our advertising campaigns, to carry out market research and to deliver advertisements in line with your interests.

When you visit our website, a banner will appear informing you of our use of cookies. You will be able to disable certain types of cookies, but you will not be able to disable essential cookies.

You may change your cookie choices at any time by configuring your device settings or by redisplaying the consent banner: Cookie settings.