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CANADIAN PHARMACEUTICAL DISTRIBUTION NETWORK PRIVACY STATEMENT

Canadian Pharmaceutical Distribution Network (“CPDN”, “we”, “us” or “our”) takes steps to ensure we meet privacy principles and requirements with respect to personal information under applicable Canadian privacy legislation. The purpose of this privacy statement (the “Privacy Statement”) is to inform the healthcare professionals we deal with (“you” or “your”) how we collect, use, disclose and protect your personal information. Personal information is information about an identifiable individual, as more particularly described under applicable privacy legislation. This Privacy Statement applies to our collection, use and disclosure of personal information in Canada. This Privacy Statement does not apply to information about our employees or to information that is not personal information.

PERSONAL INFORMATION WE COLLECT

CPDN collects personal information in the course of services we provide to healthcare professionals. In particular, CPDN collects personal information to facilitate the ordering and distribution of pharmaceutical products, including narcotics and controlled substances. Personal information we collect includes:

  • name, address, email address, telephone number, and other contact information;
  • license number issued by your professional regulatory body;
  • driver’s license number;
  • date of birth;
  • credit card or other payment and financial information;
  • purchase order information;
  • purchase history;
  • information you provide when you contact us by any means, including in person, online, by telephone or by mail; and
  • such other information we may collect with consent or as permitted or required by law.

USE OF PERSONAL INFORMATION

CPDN generally uses personal information for the following purposes:.

  • verifying that you are a member in good standing with your professional regulatory body;
  • verifying that you have the authority to order narcotics and controlled substances;
  • determining eligibility for opening an account;
  • processing and facilitating delivery of orders;
  • managing, administering, collecting or otherwise enforcing accounts;
  • maintaining business records for reasonable periods, and generally managing and administering our business;
  • meeting legal, regulatory, insurance, security and processing requirements; and otherwise with consent or as permitted or required by law.

DISCLOSURE OF YOUR PERSONAL INFORMATION

CPDN discloses personal information in the following circumstances:

  • to professional regulatory bodies in order to verify your identity and to confirm that you are a member in good standing;
  • to certification organizations that grant authority with respect to the handling and distribution of narcotics and controlled substances;
  • to manage and administer accounts including to process credit cards or other forms of payment;
  • as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, processing and security requirements; and
  • with your consent, or as permitted or required by law

Service Providers. CPDN may transfer personal information to third party agents or service providers (including affiliates of CPDN acting in this capacity) that perform services on our behalf, such as administrative and technical services, verification services, data hosting or processing services or similar services, or otherwise collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Statement. Some of these service providers may be located outside of Canada, including in the United States, and your personal information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for the purposes described in this Privacy Statements. We take reasonable contractual or other measures to protect your personal information while processed or handled by these service providers. While 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.

Business Transactions. Personal information may be used by CPDN and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of CPDN or our business or assets, including for the purposes of: permitting such parties to determine whether to proceed or continue with such transaction, and to fulfil reporting, inspection or audit requirements or obligations to such parties. Assignees or successors of CPDN or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Statement.

Legal, Regulatory. CPDN may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to CPDN or our agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).

OUR WEBSITE

Cookies. Our websites, www.cpdn.ca and www.cpdnweboms.ca (or other as designated) uses temporary session “cookies” on all of our secure pages to assign and store a session ID to you so that you can move uninterrupted between the areas of our site. This session ID is also used for internal reporting purposes. It is not personally identifiable to you, and this type of cookie does not leave any retrievable information on your hard drive. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. At no time can the cookie read any information from your hard drive, and you can remove it from your machine at any time.

Link to other websites. Certain links within CPDN’s website may take you to other websites which are not maintained by CPDN. The inclusion of such links is for your convenience only and should not be interpreted as an endorsement of the owner/sponsor of the site or the content of the site. Such websites may contain terms and conditions, privacy provisions, confidentiality provisions or other provisions that differ from the terms and conditions applicable to CPDN’s website. CPDN assumes no responsibility for the content, accuracy, validity, legality or otherwise of any materials or information contained on such sites.

YOUR CONSENT

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Further, where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures of the personal information.

CPDN collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

SECURITY

We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and mandataries of CPDN who require access to your personal information in order to fulfil their job requirements will have access to your personal information.

ACCESS, CORRECTIONS, AND CONTACTING US

CPDN may establish and maintain a file of your personal information for the purposes described above, which will be accessible at 6755 Mississauga Road, Mississauga, Ontario L5N 7Y2. If you wish to request access or correction of your personal information in our custody or control, you may write us at the above address, attention Scott Gibson, Director of Operations. Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. If you wish to make inquiries or complaints or have other concerns about our personal information practices, you may write to us as described above.

PRIVACY STATEMENT CHANGES

This Privacy Statement may be revised from time to time. If we intend to use or disclose personal information for purposes materially different or not described in this Privacy Statement, we will make reasonable efforts to notify affected individuals in advance, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us as described above or check back at our website periodically at www.cpdn.ca. (or as designated) to obtain a current copy of this Privacy Statement. We urge you to request and review this Privacy Statement frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Statement constitutes your acceptance of any such changes.

This Privacy Statement is effective as of August 1, 2016.