Reformulary Group
Privacy Policies

What you should know about our commitment to protecting the confidentiality of your personal information.

What is privacy and why does it matter?
Privacy is about more than just protecting the personal information you may share through the use of our services, or when using our website. Privacy is also about our obligation to use and disclose this information only for the purposes that are stated in our privacy policy.

We are committed to your privacy.

Our commitment to protecting your privacy
Reformulary Group’s mandate is to support our clients in receiving the maximum value from their drug plan. As we aim to provide you and our clients with the best services, we may collect, use and/or disclose personal information. Our privacy policy sets high standards for collecting, using, disclosing and storing personal information in these specific cases. We also take great care to keep your personal information accurate, confidential and secure.

This privacy policy, along with Reformulary Group’s Privacy Code, our Online Privacy Statement and our privacy practices represent the parameters within which Reformulary Group manages privacy matters and protects personal information.

This privacy policy applies to the information we may receive from you through the Reformulary Group website, including the DrugFinder web portal. If you have any questions about our privacy policy, please contact our Chief Privacy Officer at (416) 519-9729 or privacyofficer@reformulary.com.

Privacy Policy
How we collect, use and disclose personal information

We ask you for only the information we need
We will collect only the information we need for the purposes identified to you. We will not sell personal information under any circumstance.

Why we need the information
Generally, we may need to collect personal information to:

• understand your needs
• understand our clients’ specific business needs
• analyze and interpret your data to provide maximum value from drug plans
• meet legislative, regulatory or contractual requirements as well as implement risk management programs and procedures relating to the services and products provided to you.

We will make sure you understand why we need the information by using clear, understandable language.

We will obtain your permission
We collect, use or disclose your personal information with your permission.

Your permission may be expressed in writing or be implied and you may give it to us 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.

Where medical information about you is collected or released, we will obtain your consent prior to doing so. We will not share it, unless your consent has been obtained.

Before we make information available to third parties, other than an 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, 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 information
We are responsible for all personal information in our possession, including information transferred to a third-party service provider, so that we can provide you with a product or service. In some instances, our employees, service providers, and partners may be located in jurisdictions outside Canada, and your personal information may be also subject to the laws of those foreign jurisdictions. All such persons, whether or not they are located in Canada, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy policy.

How we protect information
Access to your personal information is restricted to those of Reformulary Group’s 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.

Your right to access your personal information

Your rights
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:

• how we collected your personal information,
• how we are using it, and
• to whom it may have been disclosed.

Under certain circumstances, it is possible that Reformulary Group may not be able to provide you with all of the information you may have requested. Certain fees may also be applied to any copy of the requested personal information.

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 make the necessary changes.

If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures.

How to register complaints
You may register a privacy-related complaint by contacting Reformulary Group’s Chief Privacy Officer. We will explain Reformulary Group’s 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
For more information, please contact Reformulary Group’s Chief Privacy Officer at (416) 519-9729 or at privacyofficer@reformulary.com

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 privacyofficer@reformulary.com

If you have concerns about your privacy at Reformulary Group, contact our Chief Privacy Officer at (416) 519-9729 or at privacyofficer@reformulary.com

Privacy
Your privacy is important to us. We want you to understand how we safeguard your personal information and what types of information we receive and collect when you visit our website.

Personal information and online security
When you visit the Reformulary Group website, including the DrugFinder web portal, you are anonymous unless you voluntarily choose to identify yourself. You are not required to provide personal information to use our website or portal unless a feature requires it. If a feature does require providing identifying 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 we believe are adequate to protect personal information, any such systems may be subject to human and operational error. 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 and portal - 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 and our portal’s 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 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.

Reformulary Group can use such passively collected 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; 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”. 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.

Active Information Collection
At various points on the Site, you might choose to actively provide certain kinds of information, including personally identifiable 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. With respect to all content and information you submit to the Site you represent and warrant to Reformulary Group that you have the lawful right to do so without limitation or restriction.

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. The 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. 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.

Aggregated and Anonymized Information

In an ongoing effort to better understand and serve the users of our Services, we conduct research on our customer and User demographics and behaviour based on Personal Information, Personal Health Information and other information that we have collected. This research can be used to conduct industry research, understand market trends, and provide our users with statistics and metrics that may be of interest to them. 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 the Privacy Policy. This aggregated and anonymized data may be provided to third parties, such as pharmaceutical companies and insurance companies. Reformulary Group may also develop product offerings to its clients, based on aggregated and anonymized personal health information of its employees that utilize the Services, to better understand the drug utilization of their clients and employees.

Jurisdiction
This Site originates in Canada. The laws of the Province of Ontario and the laws of Canada applicable therein shall govern as to the interpretation, validity and effect of this agreement notwithstanding any conflict of laws, provisions or your domicile, residence or physical location. You hereby consent and submit to the exclusive jurisdiction of the courts of the Province of Ontario in disputes, proceedings or claims arising out of or in connection with this Site or your use of the Services.

General
No agency, partnership, joint venture, or employment is created as a result of these Terms and you do not have any authority to bind the Services in any respect whatsoever. Any consent by a party to, or waiver of breach by the other, whether express or implied, will not constitute a consent to or waiver of or excuse for any other different or subsequent breach unless such waiver or consent is in writing and signed by the party claimed to have waived or consented. Except as otherwise provided herein, no term or provision will be deemed waived and no breach excused. These Terms constitute the entire agreement between you and Reformulary Group with respect to the subject matter hereof and cancels and supersedes any prior understandings and agreements between you and Reformulary Group. In the event that any one or more provisions contained in these Terms are held to be invalid, illegal or unenforceable, such invalidity, illegality or unenforceability will not affect any other provisions of these Terms and these Terms will be construed as if such invalid, illegal or enforceable provision had never been contained herein.

Collection of personal information from children
The Reformulary Group website is not directed at children. We do not knowingly collect information from children under the age of 18.

Language
English will be the language of the Site and the Terms, and all contents, information and communication in connection with the Site, and the parties waive any right to use and rely upon any other language or translations. Il est de la volonté explicite des parties que le présent Web Site et toutes les affairs qui s'y rapportent soient rédigés en langue anglaise, exception faite des documents pour lesquels la loi exige l'usage exclusif du français.

Please be aware that we may update and modify this online privacy statement at any time. Please review this section each time you access and/or use our website and portal.

Contact
If you have any questions concerning these Terms, please use the Contact Us page on this Site.

Contact Us
55 York Street, Suite 1400
Toronto, ON M5J 1R7
Phone: 416-519-9729
Fax: 416-519-9731
Email: askus@reformualry.com