Empego Technologies Inc. (“Empego“) has developed a platform (the “Platform“) that enables users to initiate a consultation with a pharmacist, either on-site or remotely, and that allows the user to answer, before the consultation, questions needed to prepare for the consultation with the pharmacist.
All employees and third parties working with Empego are required to comply with the commitments described in this Policy. We are committed to respecting your fundamental right to privacy and all applicable data protection laws and regulations.
Data and Personal Information that may be collected
When you use the Platform, certain personally identifiable information (“Personal Information”) may be collected, this includes:
Demographic data (“Demographic Data”) may also be collected, including:
Furthermore, certain information concerning the consultation (“Consultation Information”) may be collected, such as:
Lastly, usage data (“Software Usage Data”) may be collected from the website and Platform, which includes:
Use and sharing of Personal Information
Empego employees do not have access to your Personal Information. All Personal Information is anonymized to prevent direct or indirect identification of any user by Empego employees.
An authorized employee may access protected data, such as Personal Information, in the event of a court order or a major technical problem with the platform. The employee would first need to submit a formal request and obtain formal authorization to access any such data. This request must contain reasonable grounds justifying the need for such access. Reasonable grounds may include the need to diagnose, repair or maintain computer systems, to resolve technical problems, or other legitimate reasons related to data management. Once the request has been submitted, it will be reviewed by the appropriate parties, usually Empego’s Data Protection Officer. This person is responsible for deciding whether the grounds presented justify giving access to the data. The decision must consider the need to safeguard the security, confidentiality, and integrity of the data. If the request is approved, the authorized employee will be granted a limited and temporary access to the data, which will be specifically targeted for the purpose in question. The access granted must strictly comply with the conditions set out in the approved request. Any unauthorized access or misuse of data may have legal consequences.
In short, an authorized employee may access protected data after submitting a reasoned request and obtaining formal authorization. However, such access must be limited to a specific purpose and be in accordance with the rules established to protect data security and confidentiality.
Consultation Information and Demographic Data, may be shared with researchers, partners, or third parties in an anonymized form, without time limitation. This disclosure will always be made in compliance with applicable laws and regulations and in respect of your confidentiality. In order to guarantee the protection of our users’ privacy, Consultation Information and Demographic Data is processed in such a way that it does not allow for the identification of the person concerned. This data may be used, without limitation, for studies, research or statistical analysis, as well as for demographic, behavioral and population trends in the context of pilot projects. It may also be used for other legitimate purposes relating to the improvement of our products and services, strategic decision-making, research, technological development, and the improvement of pharmaceutical practice.
Software Usage Data is collected for statistical purposes. This data is primarily used to examine traffic, to observe and analyze how users interact with the Platform, to monitor and analyze statistics, and to obtain an accurate representation for technical administration of the Platform. The aim is to increase functionality, user-friendliness, and to better adapt our Platform to the users’ needs. This type of data will not allow you to be identified.
Empego uses anonymized Software Usage Data and Consultation Information for research purposes, to analyze trends in the population, to sell to private companies and to improve the Platform. Please be assured that this data will not allow you to be identified.
If you have any questions or concerns about our use of anonymized data, please do not hesitate to contact us at the following e-mail address: email@example.com.
We reserve the right to disclose Personal Information and any other data if we are required to do so under any applicable law or if we believe in good faith that such disclosure is necessary to comply with such applicable laws.
Period of Retention
We keep your Personal Information only as long as it is necessary to fulfill the purposes for which it was collected and to comply with our legal and regulatory obligations. When Personal Information is no longer required, we securely destroy it or make it anonymous. Empego will store anonymized information indefinitely on encrypted and secure servers located in Canada.
Rights of Platform users (patients)
As users of the Platform, you have certain rights regarding your Personal Information, including the right of access, rectification and withdrawal of consent to processing. Empego employees are authorized to access your Personal Information for these purposes. The withdrawal of consent involves the destruction or complete anonymization of your data. It may therefore affect our ability, as well as your pharmacy’s ability, to provide you with certain services. We will inform you in a transparent manner of the potential consequences at the time of withdrawal of consent.
We may request additional information to verify the identity of any person who asks for access to, or who tries to makes changes to, a user’s Personal Information on the Platform. This information may include specific data related to the account on the Platform, as well as official identification. This measure is intended to prevent unauthorized access to an user’s Personal Information.
Should our relationship with your pharmacy come to an end, your Personal Information and Consultation Information will be anonymized.
You may speak to your pharmacy’s staff to exercise your rights or to obtain a copy of the Consultation Information on the Platform. The pharmacy staff must then verify the identity of the individual making any such request.
Right of Pharmacy Staff
We collect certain Personal Information from pharmacy staff to provide the Platform services. In this regard, pharmacy staff have certain rights regarding their Personal Information, including the right of access, rectification and withdrawal of consent.
Any request for access, rectification or removal from Empego’s client list must be made in writing by a person able to prove their identity to the following e-mail address: firstname.lastname@example.org.
We may request additional information to verify the identity of any person who asks for access to, or who tries to makes changes to, Personal Information. This information may include specific account or transaction data, as well as official identification. This is to prevent unauthorized access to an individual’s personal data.
Data Location and Security
We take all necessary measures to protect any Personal Information from unauthorized disclosure or access, alteration, accidental loss, destruction, or any other unlawful form of processing of Personal Information in our possession.
Personal Information in our possession is anonymized and stored on encrypted and secure servers located in Canada. We use all appropriate technical, physical and organizational security measures to guarantee the confidentiality and integrity of the data collected.
Access to Demographic Data, Consultation Information and Software Usage Data is restricted to Empego’s employees, representatives and service providers who are authorized to access such information. These individuals may only access information that is necessary for the performance of their duties. Subject to the exceptions described in this Policy, Personal Information is not accessible to Empego’s employees, representatives and service providers. Empego ensures that employees, representatives and service providers who are authorized to consult Personal Information are subject to confidentiality obligations and guidelines, with penalties for breaches of confidentiality.
While we take every measure to protect your information, it should be noted that Internet transmission methods and electronic storage methods are not foolproof. Although risks are minimized, we cannot ensure or warrant the security of any information you send or provide to us, and you do so at your own risk and peril. Nor can we guarantee that such information will not be accessed, obtained, disclosed, modified or destroyed as a result of a breach of our physical, technical or administrative safeguards.
Personal Information Sharing with Service Providers
Empego conducts business with third-party suppliers and partners who provide, among other things, development, hosting and maintenance services for the Platform. These third parties may access or process anonyized Personal Information in the course of the services they provide to us. We limit access to Personal Information to that which is reasonably necessary to enable them to perform their services and carry out their mandate. Our contracts with these service providers require them to maintain the confidentiality of Personal Information.
Use of the Platform by a Third Party or a Minor
When the Platform is used by a third party on behalf of an individual, pharmacy personnel must ensure that they obtain the individual’s consent to the collection of Personal Information and the communication by a third party of his or her Personal Information. Such consent is not required when the Platform is clearly being used for the benefit of a minor under the age of fourteen (14).
We undertake to protect the Personal Information of minors and to collect and use it solely for the purposes of using the Platform and for their own benefit, in compliance with all applicable data protection laws and regulations.
We use Software Usage Data such as Cookies to tailor our website and Platform to your preferences. It also allows us to compile statistics about the consultation and use of the Platform, so that we can improve your experience.
Application of the Policy
We reserve the right to update this Policy periodically to reflect changes in our privacy practices and to comply with the governing laws. All changes will be posted on our website and we encourage you to review them regularly.
By using our services after the effective date of a change to the Policy, you are considered to have consented to the revised terms.
If you have any questions or concerns about this Policy or our privacy practices, please contact Empego’s Data Privacy Officer at the following email address: email@example.com.
This Policy has been updated on October 26th, 2023.