Privacy policy

Your privacy is important to ZoomJar Technology Inc., the owner of the PharmaGap application, (hereinafter, “PharmaGap“, “we“, “our” or “us“). This Privacy Policy (“Policy“) applies to our activities related to our mobile applications as well as our web applications and any related service, including the website pharmagap.com (collectively, the “Application” or the “services offered“) and describes our practices regarding the collection, use and disclosure of personal information, as well as the rights you may have with respect to your personal information.

Unless expressly stated otherwise, terms defined in our Terms of Use and used in this Policy have the same meaning as in our Terms of Use.

This Policy concerns personal information collected by PharmaGap, including if you are a professional, an employer, or a representative. This Policy applies whenever you interact with us, including when you access the Application.

1. Definition of “personal information”

By “personal information” we mean any information that directly or indirectly identifies an individual (collectively, “individual” or “you“) or that could reasonably be associated with that individual. This may include, for example, your name, your contact information, your email address, and information related to an account with us (as applicable). Note that information concerning an individual’s exercise of duties within a business, such as their name and title, as well as their workplace address, email address, and telephone number, is not considered personal information.

2. What personal information do we collect?

The personal information we collect may include:

• Identifiers and contact information, such as your name, email and mailing addresses, phone number, IP address (if it allows you to be identified), your device identifier, or account information (for example, if you created an account when registering for the services offered) or your license number related to your professional activities.

• Browsing activity within the services offered, such as pages and offers viewed, opt-out preferences, email bounces, clicks, social media content, and IP addresses, if this information allows you to be identified as an individual.

• Geolocation information may be collected when you use the services offered, although this information does not always allow you to be identified as an individual.

• Messages, activities, and other information shared in the chat feature of the Application.

• Any other information you provide to us that allows you to be identified.

3. How do we collect personal information?

We collect personal information in various ways, including directly from you, from technologies used at our facilities, through online technologies (for example, when you interact with us through the Application), from third-party social networks, and from other third parties. PharmaGap also encourages you to review the privacy policies of third parties. The third parties involved may use tracking methods such as, but not limited to, cookies, to achieve their own business objectives by linking and combining information about your use of the Application with any other personal information they may have collected about you.

Specifically, we collect personal information in the following ways:

A. Directly from you
We may collect personal information directly from you, through the Application, when you create an account to access the Application or when you use the Application, by mail, email, telephone, or any other direct means within the services offered, for example, when you make a request to our customer service.

B. Through our service providers
We may sometimes receive personal information from our service providers. We may also receive personal information from other sources with your consent or when permitted by law.

C. Through online technologies
With your consent or when permitted by law, we may electronically collect certain types of information when you interact with the Application. This information helps us improve our Application and understand the actions you take when using it, and allows the Application to function properly.

To learn more about the choices available to you regarding privacy protection, please see the section How can you change your privacy choices? below.

The technologies we use include:

1. 1. • Cookies, which are small text files saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly to the Platform.
      • Web analytics tools such as Google Analytics, which uses cookies to analyze your use of the Application, to create reports on user and visitor activities, and to provide other services associated with the use of our Platform.
      • Analytics engines, which draw usage data from multiple sources and help manage and collect this data for use in personalization, interest-based advertising, content personalization, and other methods to better understand our customers’ needs and preferences.

You can delete or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features related to the services offered. To learn more about the choices available to you regarding privacy protection, please see the section How can you change your privacy choices? below.

D. Third-party social networks

We may collect your personal information if you interact with us through our social media pages and accounts (for example, Facebook, Twitter, Instagram). For example, we collect the personal information that these social media platforms allow us to collect from our followers. We may also collect any content you upload to our social media pages and accounts (including photos or videos).

We may obtain and use analytical and statistical information from third-party social networks to help us measure the performance and effectiveness of the content we post on social media, for example, by measuring impressions and clicks on content.

E. From other third parties

In certain cases, we may collect personal information from other categories of third parties, but only with your consent or as permitted or required by applicable law.

4. How do we use personal information?

We limit the collection of personal information to what is reasonably necessary to achieve the purposes for which it was collected. We may use all categories of personal information detailed in the section What personal information do we collect? to provide you with our products and services, to manage our business activities, to communicate offers and information to you that we believe may interest you, to improve your customer experience with us, and as permitted or required by law.

We use your personal information for the following purposes:

A. Providing our products and services

We use your personal information to provide our services, for example to:

1. 1. 1. • process your substitution requests (also known as “replacement”) and confirm acceptance of substitution contracts;
         • verify your identity;
         • answer your questions;
         • respond to your requests or take or verify your instructions;
         • create, administer, and maintain your accounts; and
         • manage payments related to the services and use of the Platform in accordance with the terms of use.
   1.  

B. Managing our business activitiesWe use your personal information to manage our business activities, for example to:

1. 1. • inform you of changes to your account or to the services, terms, or policies of our Platform and provide you with administrative messages, updates, legal notices, technical notices, or security alerts;
      • deploy and manage our Platform and our IT systems;
      • manage and facilitate the use of our Platform, which may include the use of cookies and other similar technologies;
      • protect ourselves and third parties against errors and fraud;
      • monitor compliance with the Terms of Use, investigate incidents, and manage claims;
      • maintain our programs, products, and services; and
      • comply with our contractual, legal, and regulatory obligations.

C. Marketing and advertising
We use your personal information to market our services by delivering relevant and personalized online or email advertising to you, including on social media platforms.

If you no longer wish to receive commercial emails, please let us know by following the unsubscribe instructions provided in each commercial email. For more details on managing your advertising preferences, see section ‎7 below, titled: How can you change your privacy choices?

D. Conducting market research and data analysis
We may use your personal information to conduct market research and data analysis by tracking and analyzing your information for the following purposes:

• improve or develop new products, services, and programs, and better understand our customers and their behaviour;
• manage and grow our business and operations;
• improve our programs, products, and services (for example, improve the Application); and
• understand how users interact with the services offered, including the Application, and ensure they function properly.

Wherever possible, we will use your information in aggregated and/or de-identified form.

5. How do we share personal information?

We may share your personal information within PharmaGap and with our service providers and certain third parties for the reasons described in this Policy and in accordance with applicable law. We will not share your personal information with unaffiliated third parties without your prior consent, except as provided in this Policy or as permitted by applicable law.

A. Within PharmaGap
PharmaGap may share personal information internally with certain employees where such sharing is necessary as part of their duties and use it for the purposes described in this Policy.

B. Professionals, employers, and representatives
We may share certain of your personal information with professionals, employers, and their representatives, only to the extent necessary to provide the services offered and for any other purposes set out in this Policy.

C. Service providers
As part of providing the services offered, we may share certain personal information with third-party service providers who provide us with services. These service providers help us operate our business, our technological systems and applications, our internal procedures, and our infrastructure. We may also share certain personal information, such as name, email address, and other contact information, with certain service providers who provide us with services such as contract processing, sending emails and mail, data hosting, advertising delivery, and analytics services (for example, tracking the effectiveness of our marketing campaigns and analyzing the use of our websites and applications).

D. Sale or transfer of business or other transaction
We may disclose personal information to a third party as part of a sale or transfer of business or assets or shares, a merger, reorganization, or financing of parts of our business (including insolvency or bankruptcy proceedings). If the transaction is completed, your personal information will remain protected by applicable privacy laws. If the transaction is not completed, we will require the other party not to use or disclose your personal information in any way and to completely delete such information, in accordance with applicable laws.

E. Other authorized grounds
Applicable laws may authorize or require the use, sharing, or disclosure of personal information without consent in specific circumstances, such as to investigate suspected or actual illegal activities, to prevent such activities, including fraud, or to assist government and law enforcement agencies. These circumstances include those where the law permits or requires it or where it is necessary to protect our corporate group, our employees, our customers, or other individuals. In such circumstances, we will only share the personal information that is reasonably necessary to disclose to achieve the intended purposes.

F. With your consent
In addition to the purposes listed above, we may, with your implied or explicit consent, share or disclose your personal information outside of PharmaGap, in accordance with applicable laws.

6. How do we manage consent?

By accessing or using the services offered or by submitting information to us as part of the services offered, including through the Application, you consent to the collection, use, and disclosure of personal information as provided for in this Policy. In certain cases, your consent may be “implied,” meaning that your permission is considered given based on your action or inaction at the time your personal information is collected, used, or shared.

We generally obtain consent when we want to use personal information for a new purpose or a purpose other than those set out at the time of collection in this Policy or in the terms and conditions of a specific product or service you have registered for, participated in, or purchased. You may have the right to withdraw your consent under applicable law (except in limited circumstances, including legal or regulatory requirements or due to your contractual obligations with us). For information on how to manage your privacy preferences, please see the section How can you change your privacy choices? below.

If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is possible, we may not be able to offer you the products, services, or information you have requested or that may otherwise be available to you, including the services offered.

7. How can you change your privacy choices?

We want you to clearly understand your choices and make informed decisions regarding your privacy options. Several options are available to you for managing your privacy preferences, including: managing your preferences in your account, where applicable, contacting us directly, or changing your browser settings on your device or, where applicable, using an opt-out feature that may be offered by a third party.

A. In your account
If you have an account with us, you can update your preferences in your account in the Application.

B. When you register or by contacting us directlyYou may choose to receive commercial email communications when you register for our programs, products, or services, or at any time thereafter through your online account(s) and within the services offered, including the Application; we may also have your implied consent to send you commercial electronic communications under applicable laws.

You may choose not to receive commercial email communications by clicking “unsubscribe” in any commercial email you receive, by following the unsubscribe instructions provided when you receive a commercial email, or, in some cases, through your online account (if you have created one).

You may also withdraw your consent to other forms of marketing and advertising or to the use of your personal information for market research and data analysis purposes by contacting the Privacy Officer as indicated in the section Who should I contact if I have questions about the protection of my personal information? Please note the following regarding withdrawal of consent or changes to your privacy preferences:

1. • Although you may have chosen not to receive commercial communications from us, we may still contact you for transactional purposes, in accordance with applicable laws (for example, for customer service, product or service information, etc.). We may also need to contact you regarding questions or information about your customer service requests; and
   • There may be a delay before all of our records reflect changes to your preferences; for example, if you request not to receive personalized commercial communications from PharmaGap, your preference may not be taken into account for a promotion already underway.

C. Using third-party opt-out functionality
With your consent or where permitted by law, we may use third parties (for example, web companies or social media platforms) that use certain technologies to analyze your browsing behaviour when you use the services offered. You can manage your privacy preferences with respect to certain third parties, such as Google, using the opt-out feature on their platforms. Please note that disabling, blocking, or deleting certain of these technologies, such as cookies, may cause you to lose functionality of certain features of our websites and applications.

For example, Google Analytics uses cookies to analyze your browsing behaviour on our websites. This information is not provided to us in a format that personally identifies you and is collected through your device’s or browser’s advertising settings. If you wish to disable Google’s ad settings, please go to https://adssettings.google.com/anonymous?hl=fr or use Google’s opt-out add-on at https://tools.google.com/dlpage/gaoptout.

For more information on interest-based advertising or to opt out of having your web browsing information used for behavioural advertising purposes, please visit http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Your web browser or device may also include features or settings that allow you to opt out of the collection of certain information through applications used for behavioural advertising purposes; for more information, check your browser or device settings.

We may also include links to other websites, including social media platforms, on our websites and the Application. For more information on social application plugins, such as “Like” buttons on X (formerly Twitter), Facebook, or Instagram and their impact on your privacy rights, please consult the relevant social media help centre (for example, the Facebook Help Centre at https://www.facebook.com/help/).

8. How do we protect personal information?

We use administrative, physical, contractual, and technical measures to protect the confidentiality of personal information and to protect personal information against loss or theft, as well as against unauthorized access, disclosure, copying, use, or modification, taking into account, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your personal information. We use reasonable safeguards to ensure that our service providers protect your personal information, regardless of where it is used or stored.

In particular, we implement internal policies and practices that protect your personal information, including:

• Designating a Privacy Officer responsible for ensuring compliance with applicable privacy laws.

• Policies and procedures that define the roles and responsibilities of our employees throughout the personal information lifecycle, limit access to such information on a “need to know” basis, and govern the retention and destruction of personal information.

• Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate protections and security standards.

Our goal is to prevent any unauthorized access, loss, misuse, sharing, or modification of personal information in our possession. We also use these safeguards when we delete or destroy your personal information.

9. Where we store personal information and cross-border transfers

We may share personal information with certain service providers who may be located outside your country or your province or territory of residence. These service providers may also access, process, or store your personal information outside of the country and province in which we are located and in which you reside.

As a result, when your personal information is used or stored outside the province or territory where you reside, it may be subject to the foreign law applicable in the place where it is stored, including any law authorizing or requiring the disclosure of information to the government, government agencies, courts, and law enforcement authorities of that place.

We will retain your personal information in accordance with our retention policies or as required or permitted by law. Once it is no longer needed, your personal information will be securely destroyed or anonymized (so that the information can no longer, under any circumstances, be used to identify you, whether directly or indirectly).

10. What are your privacy rights?

The rights described below may be exercised in accordance with the requirements and restrictions set out by law:

• Your right of access: you have the right to ask us whether we use or store your personal information. You may also request copies of such personal information.

• Your right of rectification: you have the right to ask us to correct personal information that you consider inaccurate or misleading, and to complete personal information that you consider incomplete. You may also have the right to request the rectification of your personal information if the collection, disclosure, or retention of such information is not authorized by law. This rectification may also be carried out by you directly by accessing your PharmaGap account.
• Your right to account deletion and erasure of personal data: you may request the permanent deletion of your account and the erasure of your personal data by going to the “General” section of your profile, then clicking “Delete my account.” Once you confirm, your account and personal data will be permanently deleted. If you log in using your Facebook account, you will need to follow these steps to remove access to your data;
  1. Go to “Settings & Privacy” in your Facebook account and click “Settings.”
  2. Look for “Apps and Websites,” where you will see all apps and websites linked to your Facebook account.
  3. Scroll until you find the “PharmaGap” application in the list of apps.
  4. Click “Remove.”
  5. When you confirm the removal, your application activities will be successfully removed from Facebook.

You may also request deletion of your PharmaPlan application account by sending us a request at cs@pharmagap.com.

To exercise your rights, please contact our Privacy Officer using the contact information provided in section ‎12 below, titled: Who should I contact if I have questions about the protection of my personal information?.

11. Changes to our Policy

We may make changes to this Policy from time to time. Any changes made will take effect when we post an amended version of the Policy in the Application and on the PharmaGap website. If the changes we make are significant, we will highlight them where applicable laws require it. By continuing to use the services offered after the posting of the amended version of the Policy or after you have been informed of such an update, you accept the changes made to the Policy. If you do not accept the changes to our Policy, it is your responsibility to stop using the services offered. It is your duty to ensure that you have read, understood, and accepted the latest version of the Policy. The “Effective Date” indicated at the top of this Policy indicates the date it was last updated.

12. Who should I contact if I have questions about the protection of my personal information?

If you have questions about how we handle your personal information, concerns, requests, or wish to file a complaint, please contact us using the information below:

Privacy Officer

Michel Kassar
Email: mkassar@pharmaplan.ca