Privacy Policy

Introduction and Definitions

CasaHealth Tech Inc. (“CasaHealth”) owns and operates the Pocketpills platform. The platform provides registered users with access to pharmacy services (“Pharmacy Services”) that are provided by Pocketpills Inc. and 2670271 Ontario Inc. (the “Pocketpills Pharmacies”) and access to virtual nursing and medical services (“Virtual Medical Services”) that are provided by persons authorized to provide such services (“Healthcare Professionals”).

This Privacy Policy describes how CasaHealth and its affiliates (“Pocketpills”, “us”, “our” or “we”), including the Pocketpills Pharmacies and Healthcare Professionals, collect, protect, use and disclose Personal Information in the course of your access to and use of the Site, Content and/or Services (each as defined below).

If you have any questions or concerns after reading this, please email us at: privacy@pocketpills.com.

For the purposes of this Privacy Policy:

• “Content” means any expression fixed in a tangible medium and includes, without limitation, ideas, text, comments, video, audio, images, graphics, designs, drawings, animations, logos, trademarks, copyrights, information, data, software, scripts, tasks, activities, badges and ranks, and any intellectual property therein, any of which may be created, submitted, or otherwise made accessible on or through the Site and/or Services.
• “Patient Representative” means a person who is authorized to act on the patient’s behalf to manage the patient’s prescriptions and Services.
• “Services” means all services made available by Pocketpills, including but not to the Pharmacy Services, Virtual Medical Services, and any other services accessed through the Content or the Site.
• “Site” means www.pocketpills.com, its related webpages and sites (including, without limitation, any mobile optimization website), and Pocketpills’ mobile applications.

Revisions to this Privacy Policy

By accessing the Site, submitting information to us (regardless of whether you register an account with us) or downloading, installing or using any of the Content or Services you acknowledge that you have read and understood this Privacy Policy. If you do not accept the privacy practices described in this Privacy Policy you must not submit Personal Information to us or register an account with us, access the Site or download, install or use any of the Content or Services.

This Privacy Policy was last revised as of the date that appears at the top of this page. We reserve the right to revise this Privacy Policy at any time. We will give you notice of such revisions by posting the revised Privacy Policy at www.pocketpills.com/privacy-policy. We may also communicate the changes to this Privacy Policy by other means. It is your responsibility to ensure that you are aware of the current Privacy Policy when you access or use the Site and/or Services. If you continue to access or use any of the Site and/or Services after any revisions to this Privacy Policy are posted you will be deemed to have reviewed and accepted those revisions.

Types of Information We Collect

There are two types of information we may collect through your access to and use of the Site, Content and/or Services:

• “Personal Information” means information about an identifiable individual. Personal Information may include, but is not limited to, a person’s name, email address, residential address, precise geolocation information (i.e., your specific location), telephone number, date of birth, care card or provincial personal health number, medication and prescription information, information regarding allergies, medical history, gender, insurance information, payment card information, transaction history, other billing information, occupation, employment status, and in some cases, user name. Personal Information may also include certain physical and mental health information, including but not to personal and family medical history information, details of your existing medications, existence of drug allergies, medications requested and prescription information, the name of your primary physician and his or her contact information, your provincial health number and any private health benefits number or account information.
• “Non-Personal Information” means information that does not identify you and cannot be used to contact you personally and may include non-precise geolocation information (e.g., your city). Non-Personal Information may include Usage Data (as defined below).

If you connect your Google, Apple or other third-party accounts with us, we may collect both Personal Information and Non-Personal Information from those accounts for providing our Services. This is dependent on the privacy policies or settings for those accounts. We will not share the data collected with any third party. You may choose to limit what data you provide from such third parties to Pocketpills.

The choice to provide us with Personal Information and Non-Personal Information (notwithstanding Usage Data) is yours. If you do not wish to have Pocketpills collect your Personal Information through the use of our Site, Content and/or Services, you can choose not to provide it. However, your decision to withhold particular details may limit the Services we are able to provide and make it more difficult for us to advise you or suggest appropriate alternatives to our Services. If we are unable to accommodate your requests based on the information that you have provided, we may ask for additional information so that we may better accommodate your needs.

Application of this Privacy Policy

This Privacy Policy only applies to the information that is collected in connection with your access to and use of the Site and/or Services. Pocketpills is not responsible for the actions of any third parties, the content of their websites, the use of information you provide to them or any products or services they may offer. Any information you disclose to a third party is dealt with in accordance with the privacy policies adopted by each of those third parties. Individuals are encouraged to review the privacy policies maintained by each of those third parties to understand how their information will be used by those entities to process requests. For example, we partner with third party service providers and vendors to provide access to existing payment gateways and your credit card, banking and other billing information is kept with our payment processors.

The Site, Content and/or Services may contain links to third party websites (the “Linked Sites”) that are not controlled or operated by Pocketpills. Linked Sites are offered solely as a convenience to you and do not constitute our sponsorship or endorsement of, or affiliation with those third parties. The Linked Sites are maintained by third parties who have their own privacy policies and their own terms and conditions of use. This Privacy Policy does not apply to any of the Linked Sites and Pocketpills is not responsible for any information disclosed to or collected by those Linked Sites or for the privacy practices of any operators or sponsors of the Linked Sites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. Because we cannot control the activities of third parties, we do not accept responsibility for any use of your information by such third parties, and we do not guarantee that they will adhere to the same privacy and security practices as Pocketpills. To determine how your information will be treated when accessing or using the Linked Sites, you must read the privacy policy, if any, that applies to each of the Linked Sites.

Consent

We may collect, use, and disclose your Personal Information with your consent. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the Personal Information in question. Generally, we will seek your consent at the time we collect your Personal Information, either orally, electronically, or in writing.

If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose their Personal Information as described in this Privacy Policy.

Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified herein at any time by contacting Pocketpills through the contact details provided below. You may also contact us if you wish to place conditions on your consent, or otherwise limit who may have access to your Personal Information. If you refuse or withdraw your consent, you acknowledge that Pocketpills may not be able to provide you or continue to provide you with certain Services which may be of value to you.

Collection of Information

We may collect different types of Personal Information, depending on our relationship with you. Generally, we collect the following types of Personal Information in connection with your use of the Site and our Services (not all of which may apply to you).

Use of the Site

• Information You Provide to Us. When you open an account with us, request support, or in any other way engage with the Site, we may collect information such as your name, email address, telephone number, date of birth, gender, provincial personal health number, information regarding allergies, medical history, insurance and payment information, employment status, occupation and username. We may collect this information directly from you or from a person who is authorized to act as a Patient Representative.
• Social Media Sites. If you choose to connect to our Site and/or Services through a third-party social network such as Facebook, Facebook Messenger or WhatsApp we may collect information from your profile on such third-party social networks, such as your name, username, photograph, gender and date of birth.
• Payment Information. When you make purchases through our Site and/or Services, our payment processor will collect your credit card information. We do not collect or store your credit card information. We may collect other payment-related information, such as your insurance information, policy numbers and group plan information.

Use of Pharmacy Services

When you or your Patient Representative fill prescriptions through our Pharmacy Services, you or your Patient Representative will provide the relevant Pocketpills Pharmacy with your prescription information, including the medication requested, amounts and information regarding your physician or other prescribing professional. The Pocketpills Pharmacy will use this information to fill your prescription as required. The Pocketpills Pharmacy may also contact your Healthcare Professional or other prescribing professional if additional information regarding your prescription is required, such as additional information regarding your medical history or medications. The Pocketpills Pharmacy may discuss specific medications with you or your Patient Representative via SMS, email, chat, phone call or any other means of communication.

Use of Virtual Medical Services

When you or your Patient Representative use our Virtual Medical Services, your Healthcare Professional may collect information about your physical and mental health, your health history, records of treatment and clinical notes, diagnoses and diagnostic test results, the names of your other healthcare providers or substitute decision-maker, and any other information about you that is collected in the course of providing you with the Virtual Medical Services.

Other Personal Information We Collect

• Public Forums. If you choose to make use of any public forum to share information that relates to Pocketpills, we may collect any information you publicly disclose through such means.
• In-Media Communications. If you choose to send a message to us through our message, chat, post, SMS, email or other function, we may collect any information you may disclose through such means in order to facilitate the communication.
• Push Notifications. If you choose to enable push notifications, we may collect information such as your device ID or email address in order to send push notifications to your device.
• Your Location. We may collect your precise geolocation information provided that, prior to doing so initially, you will either be informed of such practice or be prompted to allow or disallow such feature. In the event you proceed with using any of the Site, Content and/or Services or choose to allow such feature, you will have the ability to disallow it at any time thereafter by taking the appropriate steps in the applicable settings tab.
• Information You Submit to Us. If you choose to submit your Personal Information to us for any other reason in any other form, we will collect such information and use it for the purposes for which you submitted it.
• Where Permitted by Law. We may also collect Personal Information as otherwise permitted by law.

Our Use of Cookies

A “cookie” is a small text file that contains information and is stored on your computer. We generally use cookies and similar tracking technologies, such as web beacons and pixels, to automatically collect information about your use of our Site. Information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, internet service provider and/or mobile carrier, pages and files viewed, searches, operating system and system configuration information, and date/time stamps associated with your usage (collectively, “Usage Data”).

We may use Usage Data to facilitate the use of our Site, for our business or analytical purposes (including to asses Site traffic and track search criteria), and to personalize web pages according to your choices and interests.

Advertising

We may also use Usage Data to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our Site, and across third-party websites or service offerings when you leave our Site. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests. For example, we may use Google Ads to provide you with advertising based on your browsing history and search requests.

If you do not wish to accept cookies, you have the option of blocking or disabling cookies.

To accept or decline cookies associated with our Site, you may do so by adjusting your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. However, please be aware that some of our Site, Content and/or Services will not function properly if you do so and you may lose access to Services you purchased.

Note also that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. Pocketpills has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.

Do Not Track (DNT)

Do Not Track (DNT) is a privacy preference that users can set in their web browsers allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals, and, therefore, Pocketpills does not recognize DNT.

Use of Your Personal Information

Your Personal Information is primarily used to facilitate your access to the Site and to provide you with the Services. We may also use your Personal Information for administrative, analytical, research, optimisation, security and other purposes, including, without limitation, the following purposes:

• to develop and improve our Site and/or Services, and to inform the creation of future Services;
• to send you information related to our Site /or Services, including confirmations, technical notices, updates, security alerts, information related to product safety or recall issues and support and administrative messages;
• to process transactions for the Services;
• to manage your account with Pocketpills;
• to attempt to contact you regarding product safety or recall issues;
• to track your access to and use of our Site and/or Services to help us learn more about your Site and/or Services access and usage, Content consumption and understand your preferences and tendencies so that we can personalise your experience, provide you with offers and notifications that are tailored to you, and otherwise enhance your experience when viewing Content and using our Site and/or Services;
• to personalise your Pocketpills Content and offers;
• to respond to customer service inquiries;
• to troubleshoot problems with the Site and/or Services;
• to enforce ourTerms of Use;
• to protect against unlawful activities or other misuse of the Site, Content and/or and Services or for other security reasons;
• to conduct marketing, including promotional activities such as running marketing or advertising campaigns with third party marketing and advertising partners to promote the Site and/or the Services;
• to provide you advertising that better suits your interests and profile and is age/gender-appropriate and targeted to your interests or general location or both;
• to compile statistics;
• to send you push notifications (if you choose to allow that function); and
• for any other purpose to which you consent or that is otherwise permitted or required by law.

By providing Personal Information through the access to, or use of, our Site, Content and any of our Services, you acknowledge and agree that we may use the Personal Information for the purposes set out in this Privacy Policy.

Updates and Push Notifications

We may occasionally send you updates, patches and related push notifications that may be of importance to you. If you do not wish to receive updates, patches and notifications you should discontinue use of our Site, Content and/or Services or disconnect your computer or device from the Internet.

If you do not wish to receive push notifications, you can disallow this function through the settings on your mobile device.

Opting Out of Marketing Communications

If you no longer want to receive marketing-related e-mails from us, you may opt out by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information below.

If you opt out from receiving marketing-related e-mails, we may still need to send you communications about your use of our Services or other matters.

Disclosure of Information

We generally identify to whom, and for what purposes, we will disclose your Personal Information (and we obtain your consent to such disclosure) at the time we collect your Personal Information.

If you are a patient who receives Pharmacy Services or Virtual Medical Services, your Personal Information may be shared among the Pocketpills Pharmacies, your Healthcare Professional, and other healthcare providers such as physicians, nurses, or lab technicians, to facilitate the provision of your healthcare. This helps to coordinate care and ensure that everyone involved in your healthcare has the right information to meet your healthcare needs. For example:

• We may need to disclose your Personal Information to a third party licensed pharmacy and a prescribing physician in order to fill your prescription(s).
• We may disclose your Personal Information to your provincial and/or private health plan as a matter of convenience for payment for your receipt of Services.
• We may disclose your Personal Information to PharmaNet, if you are resident in British Columbia, or such other prescription drug information system as required by applicable law in your applicable jurisdiction.

We may also disclose your Personal Information to a third party vendor whose products or services you have requested in order to deliver those products and services to you. Such third parties may keep and use your Personal Information whether or not you purchase their products or services. Your Personal Information will be subject to their privacy policies, so you should contact them directly for information or to voice your concerns in respect of their policies.

We may also disclose your Personal Information if we reasonably believe that we are required to do so by law or legal process or if we are otherwise requested by any law enforcement officer or agency acting under colour of law. In addition, we may disclose Personal Information in order to: (a) enforce the Terms of UseTerms of Use; (b) investigate and/or take action against unlawful activity, suspected abuse or unauthorised use of the Site and Services; (c) protect and defend the rights or property of Pocketpills; or (d) act in urgent circumstances, including medical emergencies, to protect the safety or security of the public or users of the Site and/or Services. Subject to applicable privacy laws, we may also disclose your Personal Information in connection with a business transaction such as a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information and if we do so, we will notify you that such a transaction has taken place and that your Personal Information has been disclosed.

We may also share aggregate or anonymized information, which no longer constitutes your Personal Information, with service providers, business partners, and other third parties, to the extent permitted by applicable law, for purposes that include marketing, analytics, research, and service optimisation.

We may transfer your Personal Information to our subsidiaries, affiliates and services providers that we engage to provide services on our behalf, such as web hosting services, credit card payment processing, provincial/private health plan coverage, pharmacy software providers, order processing and delivery, provided that such third parties have agreed to comply with legally required privacy standards and agree to use the information only for the purposes for which it is provided. Pocketpills will only provide those third parties with the Personal Information that they need to deliver the services to Pocketpills or on Pocketpills’ behalf.

Protection of Your Information

As required by applicable privacy laws, Pocketpills has implemented reasonable physical and technical measures to protect the information we collect or are provided with from unauthorized access and against loss, misuse or alteration by third parties.

We work hard to protect your Personal Information from unauthorized access, alteration, disclosure, or destruction. Here are the measures we take to ensure the security of your information:

• We use encryption to keep your data secure while in transit and at rest.
• We employ of a range of security measures like multifactor authentication and masking to help us protect your account.
• We constantly review our information collection, storage, and processing practices, including our subprocessors, to prevent unauthorized access to our systems.
• We undergo security training and compliance audits, and adhere to the regulations put forth by law and applicable health regulatory colleges.

We do not warrant or represent that your Personal Information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE EXPRESSLY DISCLAIM ANY GUARANTEE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION.

For further information on how we safeguard information we collect or are provided with, visitwww.pocketpills.com/security or contact us via email at privacy@pocketpills.com.

Retention of Your Information

We generally will retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, and for a longer period when permitted or required by law. For example, Pocketpills retains Personal Information associated with your account and the use of our Services for as long as you maintain an account with us and for a limited period of time thereafter. Pocketpills Pharmacies and Healthcare Professionals may retain Personal Information relating to your use of Pharmacy Services and Virtual Health Services for a longer period of time, as required by law and health regulatory guidelines.

International Transfer of Personal Information

Currently, Pocketpills or our third party service providers retain and store information collected by, or provided to, us in the cloud and on secure servers in Canada and in other jurisdictions. While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada. Those laws may require disclosure of your Personal Information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, contact us using the contact information below.

Account Security

If you access our Site and/or use any of our Services, you are responsible for protecting the confidentiality of your account password and elected codes, and for restricting access to your computer, device or media system platform, and you agree to accept responsibility for all activities that occur under your account. Please notify us immediately if you detect suspected breach or misuse of your account.

Access and Accuracy

You are responsible for ensuring that all information created through your access to and use of the Site and/or Services is accurate, reliable and complete and you acknowledge and accept that the use of such information is at your own risk. We ask that you keep the Personal Information that you provide to us current and correct. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.

You may access and update most of the Personal Information we have collected about you through your online account. You may also request access to your Personal Information (to the extent we, a Pocketpills Pharmacy, or a Healthcare Professional are in possession of any) if you submit your request for access via privacy@pocketpills.com, and we will provide you with any such Personal Information to the extent required by applicable laws.

If you believe that the Personal Information about you that is maintained by Pocketpills, a Pocketpills Pharmacy, or a Healthcare Professional is inaccurate or incomplete, you may notify us by describing in detail any inaccuracies or omissions via email at privacy@pocketpills.com. If you demonstrate that your Personal Information is inaccurate or incomplete, we will either: (a) amend or correct your Personal Information to reflect corrected or additional information provided by you, or (b) in connection with your Personal Information, make note of any claimed inaccuracies or omissions reported in the notice submitted by you. We may transmit the amended information to third parties to whom we have disclosed your Personal Information, including the Pocketpills Pharmacies and your Healthcare Professionals.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. We will not charge you any fees to access your Personal Information in our records without first providing you with an estimate of the approximate fees, if any.

Our Policy Regarding Children

Pocketpills recognizes the privacy interest of children, and our Site, Content and/or Services are not intended for children under the age of 14 and we do not target our Site, Content and/or Services to children under the age of 14. Pocketpills does not knowingly collect or use any Personal Information from children under the age of 14 unless provided by a parent or guardian using the Site and/or Services on behalf of such minor. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, please contact us at privacy@pocketpills.com. We will delete such information from our files within a reasonable time.