Privacy Commitment

TELUS Health Virtual Pharmacy policy to protect your privacy

Here’s the summary:

Here’s the detail:

We have developed this TELUS Health Virtual Pharmacy Privacy Commitment to provide You with specific details about how TELUS Health Virtual Pharmacy collects, uses, discloses and stores Your Personal Information, which includes Your Personal Health Information, when You use the TELUS Health Virtual Pharmacy mobile app, visit our website available at

The Privacy Commitment reflects the requirements of applicable Canadian privacy legislation, including provincial and federal privacy laws, and our own continuing commitment to privacy.

Please read this Privacy Commitment carefully. By accessing or using TELUS Health Virtual Pharmacy, You consent to the collection, use, disclosure and storage of Personal Information in accordance with this Privacy Commitment.

Definitions

The following definitions apply to this Commitment.

1. the name(s) of your pharmacist(s) at each visit;

2. patient identification (i.e., name, address, phone number, personal health number, contact person in case of emergencies, date of birth and gender) and a medical history;

3. pharmacy Services you receive through TELUS Health Virtual Pharmacy, such as records of treatment, profile of drugs provided (including dose, quantity, cost, coverage and prescribing physician), new prescriptions and prescription refills;

4. allergies and medical conditions; and

5. a record of appointments that You may have booked with a pharmacist, including missed and/or cancelled appointments.

Personal Information does not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.

Accountability

Consent

Here’s the summary:

Here’s the detail:

WWhen You use TELUS Health Virtual Pharmacy, You consent to our collection, use, disclosure, and storage of Your Personal Information in accordance with this Privacy Commitment.

You can withdraw Your consent to the collection, use and disclosure of Your Personal Information, subject to our legal or contractual restrictions. However, if You refuse to provide certain information or withdraw Your consent, this may limit our ability to provide You with certain Services, products and functionalities.

If You want to delete Your account, we may retain certain information to meet our legal or regulatory obligations. For example, it is a legal and regulatory requirement for all pharmacies in Canada to retain Personal Information that forms part of Your Patient Record for a period of time set out in applicable laws and regulations. Please review the ‘Retention’ section below for more information on our retention practices.

To delete Your account, navigate to the ‘Settings’ option under the ‘My Account’ menu and select the ‘Account’ option. Next, click the ‘Delete account’ link at the bottom of the page and follow the prompts.

To collect, use or disclose Personal Information outside of the purposes contemplated in this Privacy Commitment, we will seek additional consent from You.

Individuals under the age of majority in their jurisdiction of residence may not create an account on TELUS Health Virtual Pharmacy, but a parent or legal guardian may create a user profile for a minor on the parent’s or legal guardian’s own account.

Collection and Use of Personal Information

Here’s the summary:

Here’s the detail:

By creating an account with TELUS Health Virtual Pharmacy, You will have access to consultations with pharmacists by phone or video, and related healthcare Services (i.e., prescription Services), as well as other tools to help You manage Your healthcare through the app.

We only collect and use Personal Information for the following purposes:

To establish and maintain our relationship with you

After You create an account and before using any pharmacy Services, You will need to complete Your profile in the app which the pharmacy will use to create Your Patient Record. After You create an account and before using any pharmacy Services, You will need to complete Your profile in the app which the pharmacy will use to create Your Patient Record. You will need to provide Your phone number, gender, address, and any health conditions or allergies. You can also provide Your insurance and health card information if applicable. Once You have a Patient Record, You will have access to all of our Services, which may include pharmacy consultations, initial prescription counseling, and prescription first-fills and refills. Any changes to this information is validated by a pharmacist before it is made to Your Patient Record.

To provide health-related and well-being services to you

For prescription-related Services, such as filling an applicable prescription, we will need a copy of Your prescription from Your physician (sent to us by mail or directly by Your physician). Depending on Your location, You may have the option to submit an image of Your applicable prescription to begin the fulfillment process. To verify the image, the pharmacist will contact Your prescriber prior to delivering Your prescription to obtain confirmation, or You will be asked to mail in the original prescription. We also need Your address and other contact information to be able to deliver prescriptions to You.

If You wish to have some or all of Your medications at TELUS Health Virtual Pharmacy, You can initiate the transfer of Your medications from within the TELUS Health Virtual Pharmacy app.

In Quebec, Pharmacie Jérôme-Henri Lavoie (de Celles) Inc. is responsible for the security of their physical location.

To develop, enhance or market our products and services

You can opt out of receiving marketing messages from us at any time by following the unsubscribe instructions included in each of our marketing messages or by contacting us at

To maintain the security, performance, and functionality of the TELUS Health Virtual Pharmacy Website and App

De-Identification and Aggregation

1. To protect Your privacy and the security of Your Personal Information;

2. To conduct analytics and/or research in a privacy protective manner to:

   1. better understand and improve TELUS Health Virtual Pharmacy and our service offerings;

   2. operate and expand our business opportunities; and

   3. improve health outcomes.

We may use such aggregated de-identified information or insights to assist in research, planning, or product and Service development.

Sharing and Disclosure of Personal Information

Here’s the summary:

Here’s the detail:

We may share or disclose Personal Information for the following purposes:

When You share a profile within Your account, You will be sharing all current and past prescriptions You can see in the prescriptions section of the Virtual Pharmacy app. This includes all prescriptions filled by TELUS Health Virtual Pharmacy [formerly Alliance Pharmacy Group, and in Quebec Pharmacie Jérôme-Henri Lavoie (de Celles INC)]. Some of these prescriptions may be from a third party virtual care provider.

We strive to minimize the amount of Personal Information that we share with our
service providers and partners and require that it not be used for any other purpose. Our service providers may be located in Canada, the U.S. or other foreign jurisdictions.

Access, Corrections, and Accuracy of your Personal Information

Here’s the summary:

Here’s the detail:

You may request access and corrections to the Personal Information we hold about You at any time, subject to limited exceptions. Upon written request, we will also provide You with a list of individuals or entities (e.g. third party service providers) with whom we have shared or disclosed Your Personal Information, if applicable. Please contact us directly on the TELUS Health Virtual Pharmacy platform or by email at

We rely on You to ensure that the Personal Information on the TELUS Health Virtual Pharmacy platform is accurate, complete and up-to-date. You are welcome to make changes or request deletions or corrections to Personal Information on TELUS Health Virtual Pharmacy at any time by updating Your account profile on the TELUS Health Virtual Pharmacy app or by contacting us at

For a copy of Your Personal Information, please contact us on the TELUS Health Virtual Pharmacy platform or by sending us an email at [email protected]. We will take reasonable steps to verify Your identity before granting access or making corrections. In addition, Your right to access or correct Your Personal Information is subject to certain legal restrictions.

Storage and Location of Your Personal Information

Here’s the summary:

Here’s the detail:

Your Patient Record is encrypted in transit and at rest, and stored on a third party cloud platform with data centers physically located in Canada. As with most cloud platforms, in order to ensure availability, redundancy, and reliability, third parties operating these cloud platforms may temporarily view, access, use, or transfer information stored in these data centers outside of Canada as necessary for installing, implementing, maintaining, repairing, troubleshooting, or upgrading their cloud platform. To ensure this information is safeguarded at all times, we make sure that any information stored on these data centers are always encrypted in transit and at rest.

We also use service providers who may access or store Personal Information, excluding Your Patient Record, in the United States or other jurisdictions. For example, to send notifications to You that Your prescription has been shipped, we use a third party service provider solution to manage these notifications. The notification will not contain any information about Your actual prescription or what that prescription is.

Retention

Here’s the summary:

Here’s the detail:

We retain Personal Information only for as long as necessary to fulfill the purposes described in this Privacy Commitment or as required to meet legal or regulatory requirements. We may also create and retain de-identified information, and continue to use this information in accordance with this Privacy Commitment.

At Your request, we will delete Your Personal Information unless we are required to retain it to meet our legal or regulatory obligations.

Patient Records must be retained in accordance with provincial retention guidelines. In general, for Patient Records, we will follow a retention of 10 years from either the date of last entry or from the age of 19 (nineteen) of the individual to whom the information relates, whichever is later.

Safeguards

Here’s the summary:

Here’s the detail:

We understand that data security is a critical priority and we are committed to safeguarding the Personal Information in our custody and control. We have implemented a comprehensive information security program that includes written policies and procedures, and security controls, as well as reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, loss, modification, and disclosure of Personal Information in our custody or control.

Our team members must complete privacy and security training before they have access to any Personal Information, and must complete annual privacy and security training for ongoing access to Personal Information.

TELUS Health Virtual Pharmacy ensures that the security policies, procedures, and controls meet industry and TELUS best practices and are regularly tested.

Please keep in mind that no internet or email transmission is ever fully secure or error free and no security system is impenetrable. We cannot fully guarantee the confidentiality of any information that You provide to us but we can assure You that we will use reasonable and appropriate security controls, reflective of the sensitive nature of Personal Health Information.

It is important for You to play an active role in the protection and safeguarding of Your Personal Information. It’s important to guard Your privacy when You are online. If TELUS Health Virtual Pharmacy contains links to other websites, this Privacy Commitment does not govern those websites. You should read their privacy policies and make an informed decision about whether You want to use those websites or their Services.

Changes to this Privacy Commitment

Here’s the summary:

Here’s the detail:

This Privacy Commitment may be updated from time to time to reflect changes to our practices or changes in provincial or federal legislation, or college requirements. Any notices regarding modifications to this Privacy Commitment will be in written form and provided to You on the TELUS Health Virtual Pharmacy platform and on our website.

If any changes to this Privacy Commitment are significant, we will provide a more prominent notice (including email notification, if appropriate).

We encourage You to periodically review our Privacy Commitment for the latest information on our privacy practices and to contact us if You have any questions or concerns.

Questions, Complaints, and Contact

Here’s the summary:

Here’s the detail:

Please contact us at

If You have concerns with our Privacy Commitment or privacy practices, we encourage You to first bring Your concerns to us at

To contact the applicable privacy commissioner, please visit the following websites:

Alberta:

British Columbia:

Manitoba:

New Brunswick:

Newfoundland and Labrador:

Northwest Territories:

Nova Scotia:

Nunavut:

Ontario:

Prince Edward Island:

Quebec:

Saskatchewan:

Yukon:

Federal: