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PRIVACY POLICY

Murale Privacy Policy

At Shoppers Drug Mart, we respect your privacy and take great care in protecting your Personal Information. This policy demonstrates our commitment to your privacy. Read on to discover how your Personal Information is being protected.

A. Scope & Interpretation

This policy applies to Shoppers Drug Mart Inc. and its affiliates and subsidiaries, which:

1. Own stores that operate under the names Shoppers Home Health Care® and Murale®; and
2. License the operation of retail drug stores and medical clinic pharmacies under the names Shoppers Drug Mart® (Pharmaprix® in Québec) and Shoppers Simply Pharmacy® (Pharmaprix Simplement Santé in Québec) (owned and operated by Associate-Owners, who are individually responsible for compliance with this policy).

It also applies to websites operated by Shoppers Drug Mart Inc. and such affiliates and subsidiaries.

All references in this policy to “Shoppers Drug Mart” and to “us”, “we”, or “our” refer to all or any of the foregoing. This policy does not apply to certain related companies of Shoppers Drug Mart Inc., such as Loblaw Companies Limited, Shoppers Drug Mart Specialty Health Network Inc., MediSystem Technologies Inc. and MediSystem Pharmacy Limited and Personal Information held by them is governed by separate privacy policies.

In this policy, we explain what Personal Information we collect, and how we use, share and manage it.

Please note that when you visit one of our websites, sign up for, participate in or purchase a specific product, service, program, contest, promotion or event available through Shoppers Drug Mart, additional terms and conditions may be provided regarding the collection, use or sharing of Personal Information in connection with that product, service, program, contest, promotion or event. Those terms and conditions will apply together with this policy. For example, the collection, use and sharing of personal information with respect to your membership in the Shoppers Optimum Program® is subject to the privacy provisions set out in the Terms and Conditions of the Shoppers Optimum ProgramTM and this policy.
Personal Information

“Personal Information” as used in this policy means information about an identifiable individual, such as the name and date of birth of that individual, and includes non-personal information that we link to Personal Information.

This policy does not apply to the collection, use and sharing of Personal Information by companies with which we have business relationships. However, if we receive from such entities Personal Information or non-personal information that we link to Personal Information, then this privacy policy will apply to the collection, use and sharing of that information.

What Personal Information is Not

This policy does not cover non-personal information, which is information that does not identify you. However, as stated above, when we collect non-personal information and link that non-personal information to an identifiable individual, then that information will become Personal Information and become subject to this policy.

B. Consent

Unless permitted or required by law, Shoppers Drug Mart will not collect, use or share Personal Information without first obtaining consent. We will obtain consent when we want to use Personal Information for a new purpose or for a purpose other than those stated at the time of collection, in this policy or in the terms and conditions of a specific product, service, program, contest, promotion or event you signed up for, participated in or purchased.

Consent can be “express” through words or by specific acts or “implied” by the conduct of the individual whose Personal Information is being collected, used or shared. Unless we determine that we require an additional consent for specific products, services, programs, contests, promotions or events, you agree and consent that as a provider of Personal Information, we may collect, use, share or otherwise process your Personal Information in accordance with this policy.

You may withdraw your consent for certain purposes. For example, you may choose not to receive:
• information addressed to you personally about products, services, programs, contests, promotions or events offered by Shoppers Drug Mart, affiliated companies or companies with whom we have business relationships; or
• invitations addressed to you personally to comment on the products, services, programs, contests, promotions or events that you use or that are available to you.

However, because of legal or regulatory requirements that we have or contractual obligations you have with us, there are limited circumstances where you may not withdraw your consent to the collection, use or sharing of your Personal Information. If you choose not to provide us with certain Personal Information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the products, services, programs, contests, promotions, events or information that you requested or that could be offered to you. For example, if you withdraw your consent to the sharing by an Associate-Owner’s pharmacy of your Personal Information with your provincial drug benefit program or your private health insurance provider, the pharmacy may be unable to transmit drug benefit claims, which means you will have to pay for your prescription and seek reimbursement afterwards. Similarly, if the pharmacy is unable to consult with others who provide you with care, they may, using their professional judgment, decline to fill a prescription.

Please also be aware that, even if you have withdrawn your consent to receive marketing communications from us, we may continue to contact you for certain non-marketing purposes necessary for the management of our businesses, as required by law or related to products, services, programs, contests, promotions or events that you had signed up for, agreed to participate in or purchased.

To withdraw or limit your consent, you can contact us as described below in “Answering Your Privacy Questions”. If you have a product, service or program, such as a credit card, or are participating in a contest, promotion or event, that is offered by a third party together with Shoppers Drug Mart or under a Shoppers Drug Mart brand, you may also have to provide your consent preferences or withdraw your consent with that third party separately.

Please note that it may take some time for all of our records to reflect changes in your preferences. For example, if you request that you not receive personalized marketing communications from Shoppers Drug Mart, your preference may not be captured for a promotion already in progress.

C. How We Collect Personal Information

Shoppers Drug Mart collects Personal Information in a variety of ways such as during the course of your purchase of, or application or request for a quote for, our products and services or your participation in one or more of our programs, contests, promotions or events. Shoppers Drug Mart limits the collection of Personal Information to what is reasonably required.

Shoppers Drug Mart collects Personal Information in the following ways:

Directly From You. You may provide Personal Information to us in person, by mail, over the telephone, through our websites or in any other direct manner. For example, Personal Information may be collected through our monitoring and recording of communications, such as telephone calls to our call centres.

From Related Companies. We may receive Personal Information from related companies. Any such disclosure to us by a related company will be done in accordance with that company’s privacy policy.

From Third Parties. Occasionally, we may receive Personal Information from other sources if we have obtained your consent to do so or if the law permits us to do so.

Through Technology. We may collect Personal Information and non-personal information through various technologies directly from you or from third parties.

Point-of-Sale: We may receive non-personal information from sources such as our own and third party point-of-sale-systems and when we link that non-personal information to an identifiable individual it will become Personal Information.

Video surveillance: We may collect Personal Information through video surveillance in areas surrounding our stores, kiosks, pavilions, bank machines, parking lots and other locations for security purposes, to protect against theft, damage to property and fraud, and may use this information to help us better understand the flow of traffic in our stores.

Websites, Social Media, Applications and other electronic means: We may collect Personal Information and non-personal information electronically, directly from you or through third parties. For instance, we may access Personal Information about you when you share information about yourself on social media networks and also when you interact with us electronically such as through our information technology systems, websites, email, mobile applications, social media properties or online advertising. For example, when you visit one of our social media sites, we may collect Personal Information that you choose to submit to us such as your name, contact information, opinions or any other information you choose to provide for the purposes of responding to an enquiry you have made, or for any other purpose disclosed to you at the time of the collection. Third parties may provide information about you to us, such as search terms you used, or refer you to us as a result of a search you conducted.

When you interact with us, such as when you visit our websites or click on our ads, we may use, and send to your device or computer, cookies, web beacons, single-pixel gifs and other technologies to help us collect and store Personal Information or non-personal information about you or to enable us to present offers to you, including interest-based ads. These technologies are used to help us understand what actions you take on our own and on third parties’ websites and applications. For instance, we may store Personal Information and non-personal information, such as your name, email address, province and language preference, on one of these technologies to enable us to populate entry fields that you have previously completed, or present you with content specific to your region and language preference.

We may also record user and usage data, such as where users click on a page, the internet protocol (“IP”) address, operating system, which website or ad the user clicked on to reach our website and which search terms were used, to help us optimize our websites, generate reports, display interest based advertisements, or understand which key words result in visits to our websites. You may delete or disable certain of these technologies, such as cookies, at any time via your browser. However, if you do so, you may not be able to use some of the features of our websites.

When you visit our websites, we may place, or we may allow third party companies (such as advertising networks) to place cookies or web beacons on your computer or device to collect information (not including your name, address, email address or telephone number) about your visits to our websites, as well as your other online activity, which may be tracked and used, in combination with other information about you, by us or these third party companies to provide advertisements on our websites and other websites about goods or services that may be of interest to you. You may delete or disable certain of these technologies, such as cookies, at any time via your browser.

If you choose to download or use a mobile or location based application (“app”) created by or for Shoppers Drug Mart, we may receive Personal Information and non-personal information about your current location and about your mobile device, tablet, or browser, such as a unique identifier for your device. Most devices, tablets and browsers allow you to turn off the tracking of your location. However, if you do so, you may not be able to use some or all of our apps.

D. How We Use Personal Information - Purposes

We identify the purpose for which Personal Information will be used typically at or before the time the Personal Information is collected. Our use of Personal Information is limited to the purposes described in this policy, the purposes set out in the terms and conditions of any product, service, program, contest, promotion or event in connection with which Personal Information was collected, purposes required by law and purposes consistent with any of those purposes. As new purposes may develop over time, we may update this policy so we encourage you to review this policy periodically online.

Shoppers Drug Mart collects, uses and shares Personal Information for the following purposes, which involve, among other things, the activities described for each:

Healthcare

In connection with the provision of healthcare services, which includes:
• Dispensing your medications and providing initial and, where appropriate, on-going counseling with respect to your prescription;
• Delivering pharmacy professional services and, where appropriate, providing knowledge, information and counseling in connection with such services, such as immunization information, adaptation of prescriptions, initiation of prescriptions, medication reviews etc.;
• Communicating with you to advise you of prescription refills and other health-related information and services that may be of assistance or interest to you;
• Assisting physicians and other healthcare professionals as needed;
• Responding to requests made by, or on behalf of, your insurance provider to review your insurance claim(s);
• Recommending products, services, programs or events to manage your healthcare needs;
• Managing your patient record, including medications dispensed and services provided;
• Obtaining and processing payments for prescription medications and pharmacy services;
• Monitoring and investigating incidents and managing claims;
• If requested, referring you to other healthcare providers, such as Certified Diabetes Educators or other health professionals; and
• Performing obligations in accordance with, or complying with, applicable healthcare-related professional, legal or regulatory requirements. Provision of Products, Services, Programs, Contests, Promotions or Events

To provide products, services, programs, contests, promotions or events, which includes:
• Creating, administering, and maintaining accounts, such as for loyalty or warranty programs, which may include processing your application or providing a quote for a product, service or program, verifying your identity, determining your eligibility for a product, service or program, or protecting parties from errors and fraud; and
• Processing your transactions and returns (including, for example, loyalty redemptions), or contacting you about special orders.

Business Management

In order to manage our businesses, which includes:
• Maintaining the security of the public and customers, employees and property;
• Maintaining quality service levels and to assist in training staff and service providers;
• Deploying and managing our information technology applications and systems, including to troubleshoot a problem or to test systems including before a change is deployed throughout a system (we use non-personal or anonymized information for such purposes as much as possible); and
• Managing and facilitating the use of our websites and mobile applications, which may include using cookies and other similar technology.

We or a third party use cookies, web beacons and other site-related technologies for various purposes including session management, traffic monitoring, personalization, transactions (e.g. credit card sales), marketing or promotional purposes, to better understand which web, mobile or other electronic features you use, or to improve or to develop new products, services, programs, contests, promotions or events. For example, we may use cookies to count the number of visitors to our websites, and to compile aggregated information on websites and user activity to help us improve the functionality of our websites. Please refer to the section titled “Through Technology” in Part C “How We Collect Personal Information”, and also to the terms of use on our websites, social media sites and mobile applications for more information about the Personal Information and non personal information that is collected on those sites and applications and the purposes for which that information is used.

Communication

In order to communicate with you, which includes:

• Informing you about special offers and promotions or products, services, programs or events that Shoppers Drug Mart reasonably believes may be of interest to you;
• Enabling your participation in contests, promotions, surveys, chats, seminars or workshops, including contests where entry is automatic;
• Taking or verifying instructions from you;
• Responding to your enquiries;
• Providing you with information about the products, services, programs, promotions, contests and events you currently have or are participating in;
• Recommending particular products, services, programs, promotions, contests or events to meet your needs;
• Providing you with offers or services based on the location provided by your mobile device (also referred to as location based advertising) or based on your interests;
• Establishing a record of the Personal Information you provide or that we receive about you; and
• Communicating changes to Shoppers Drug Mart’s policies or procedures that affect you, including this policy.

Unless you tell us otherwise or consent is required by law, we may contact you by any means for which you have provided contact information.

Market Research

In order to understand current and future consumer interests, which includes:
• Conducting market research by tracking and analyzing current or previously collected information such as purchases, web activities (including offers viewed, opt-out preferences, bounces, click-throughs, content on social media and IP addresses) and other transactions (including the number and amount of transactions by type, location/store of purchase, product code information, brand, quantity purchased, date, time, payment method used, promotional offers used in connection with the transaction, etc.), shopping patterns, account balances, account numbers, payment history, account activity, use of mobile device (including use of features, and duration, frequency, type and location of calls and text messages), and the methods used to apply for or to access or use products, services, programs, promotions, contests or events;
• Using information from these marketing, research and statistical analyses to improve or to develop new products, services, programs, promotions, contests or events, to better understand you and communicate with you as set out above.

Please note that personal health information, as that term is defined in law, such as prescription or medical information, is not shared for market research purposes among Shoppers Drug Mart, its affiliates, subsidiaries or related companies.

E. How We Share Personal Information

Where permitted by law, we share Personal Information within Shoppers Drug Mart for the purposes described in this policy. Please note, however, that personal health information or financial information is only shared within Shoppers Drug Mart on a limited basis, such as to process a prescription related claim or a credit card transaction and is not shared for marketing purposes (although may be used by the company to which it was provided for some marketing purposes.)

Subject to the provisions of this policy, we may also share Personal Information and non-personal information, for the purposes described in this statement, with related companies. These related companies are not governed by this policy, but have in place their own policy or policies as well as appropriate safeguards for the protection of Personal Information. For example, we may share your purchase history and other information about you with Loblaw Companies Limited and its affiliates and subsidiaries, current and future, and our other affiliates to help improve our respective products and services, better understand your shopping and information needs and communicate with you. Please note that if you joined the Shoppers Optimum Program prior to the Effective Date of this policy, the information collected in connection with your membership in this loyalty program will be shared with Loblaw Companies Limited, and its affiliates and subsidiaries, current and future, only with your consent.

We may also share Personal Information about you with other organizations outside of Shoppers Drug Mart that help Shoppers Drug Mart provide products, services, programs, promotions, contests or events or help us with our business operations. These other organizations may include sub-contractors, third party service providers, third parties that offer products, services, programs, promotions, contests or events under one of our brands, or organizations that help us improve our products, services, programs, promotions, contests or events as well as our business and technology systems, procedures and infrastructure. When Shoppers Drug Mart shares Personal Information with any such party, we limit the use of such Personal Information to those purposes requested by us and we require the party to have appropriate safeguards for the protection of that Personal Information. For example, Personal Information collected from users of Shoppers Drug Mart’s photo site, shoppersphoto.ca, is automatically transferred to Fujifilm Canada Inc., which operates this photo service on behalf of Shoppers Drug Mart.

Healthcare. When we provide you with healthcare services, we may share your Personal Information with your healthcare providers (which may also be referred to as your “circle of care”) and your authorized family members. We may also share it with others but only with your consent or as otherwise permitted by law. For example, we may share prescription information with designated individuals (e.g. parents, caregivers) who have authority to do so. All such sharing is done in a manner consistent with this policy.

We may also share Personal Information as permitted or required by law. For example, if you fill a prescription order in one of the Associate-Owner’s pharmacies, the pharmacy may share Personal Information with your provincial drug benefit program, private health insurance provider, or other health claim adjudicator as necessary in order to process your claim. The pharmacies may also, as required by law, provide prescription-related information to regulatory authorities, government bodies and/or registries.

Other sharing. Canadian law permits or requires the use or sharing of Personal Information without consent in specific circumstances. These circumstances include situations when permitted or required by law or when necessary to protect Shoppers Drug Mart, employees, customers, or others. Should this occur, Shoppers Drug Mart will not share more Personal Information than is required to fulfill that particular purpose.

Sale or transfer of business. From time to time, we may decide to sell or transfer all or part of our business to a related company or to a third party, to merge with another entity, to insure or securitize its assets, or to engage in another form of corporate or financing transaction (including transfers made as part of insolvency or bankruptcy proceedings or as part of a corporate reorganization or stock sale or other change in corporate control). In addition, the manner in which products, services, programs, contests, promotions and events are provided to you, and the organization providing those products, services, programs, contests, promotions or events, may also change. If your Personal Information is required in connection with any such transactions, we will require that the parties involved, including affiliates, advisors or other service providers, agree to protect your Personal Information with policies meeting standards equivalent to those set out in this policy both during and after completion of the transaction.

Similarly, the relationship between Shoppers Drug Mart and a third party that provides a product, service, program, contest, promotion or event under a Shoppers Drug Mart brand may cease. If that third party continues to provide a product, service, program, contest, promotion or event to you, your Personal Information will be subject to that third party’s privacy policy.

Other than as stated in this policy or as stated in terms and conditions or as part of a consent in relation to a product, service, program, contest, promotion or event, Shoppers Drug Mart does not sell, trade or share for financial or other benefit any Personal Information with third parties.

F. Retention

How We Protect Personal Information

Shoppers Drug Mart strives to maintain appropriate physical, procedural and technical safeguards with respect to the retail stores, pavilions, kiosks, offices, websites and information storage facilities so as to prevent loss, misuse, unauthorized access, disclosure, or modification of Personal Information. These safeguards also apply to the disposal or destruction of Personal Information.

We also seek to ensure that any Personal Information in our custody is as accurate, current and complete as necessary for the purposes for which we use that Personal Information.

Where We Keep Personal Information

In general, we store, access and use Personal Information in Canada. Unless there is a legal or regulatory requirement to keep such information in Canada, Personal Information may also be stored, accessed, or used outside of Canada. For instance, when we engage a service provider outside of Canada, Personal Information may be stored, accessed or used in any country where the service provider is located, or from which it provides services, including the United States, the Netherlands and India. Where Personal Information is located outside of Canada, it is subject to the laws of that jurisdiction.

How Long We Keep Personal Information

We actively retain Personal Information only as long as it is required for our relationship and a certain period of time afterwards to respond to queries or as required by federal and provincial laws. When this period ends, Personal Information is scheduled for destruction according to our record retention policies. Depending on the nature of the Personal Information and the purpose for which it was collected, this schedule may vary.

G. Access And Dispute Resolution

Shoppers Drug Mart provides a right of access and review of your Personal Information in accordance with applicable laws, and will endeavour to provide the Personal Information in question within a reasonable time. You will be asked for identification so that we may verify your identity before providing you with your Personal Information. If you require the documents in an alternative format, we will make reasonable efforts to provide you with your Personal Information in that format. If there will be charges for us to retrieve or provide you with specific information that you have requested, we will advise you of the charges that you would be responsible for and obtain your authorization before proceeding.

Our policy is to respond to access requests as required by applicable laws. Shoppers Drug Mart may decline access to Personal Information in certain circumstances. These include where the information requested would reveal confidential information or Personal Information about someone else, or if legal or regulatory requirements prohibit providing access or permit not providing access to such information. To access your personal health information, a written request should be sent to the Associate-Owner of the pharmacy where your prescription records and patient file are maintained.

If you are concerned about how we treat your Personal Information, please contact the appropriate Privacy Officer using the contact information set out below in “Answering Your Privacy Questions”.

If the Privacy Officer is unable to address your concern to your satisfaction, arbitration may be an option recommended to you to settle the dispute. Arbitration is a form of dispute resolution. If the parties decide to pursue arbitration, then the parties would refer the dispute to an arbitrator who would take into account the evidence of each of the parties and render a decision.

If you remain unsatisfied, you may bring the matter to the attention of the appropriate Privacy Commissioner. Some of our activities are subject to the jurisdiction of the Office of the Privacy Commissioner of Canada; other activities are subject to the jurisdiction of the Privacy Commissioner of your province of residence.

H. Answering Your Privacy Questions

Shoppers Drug Mart encourages you to review this policy periodically. If you have any questions about how we treat your Personal Information or wish to know what information we have in our files about you, ask a question about the information in your file or request a change to the information in your file, please contact the appropriate Privacy Officer listed below.

For enquiries about Personal Information collected online through Shoppers Drug Mart’s websites, in retail stores or through the Shoppers Optimum/Pharmaprix Optimum loyalty program, or any other general matters:

Shoppers Drug Mart
243 Consumers Rd.
Toronto, Ontario
M2J 4W8
Privacy Officer


For inquiries that relate to personal health information, please contact the Associate-Owner of the pharmacy(s) at which you received pharmacy services.

If you have a product, service, program, or are participating in a promotion, contest or event that is offered by a third party under a Shoppers Drug Mart brand, the third party may hold certain of your Personal Information. Should you have any questions or concerns, we will direct you to the appropriate contact so that you may make enquiries as to that party’s privacy policies and practices.

At Shoppers Drug Mart, we understand the responsibility that comes along with collecting, using and sharing Personal Information. In adopting and adhering to this policy, we assure you that the Personal Information we collect will be used in an appropriate and responsible manner.

Effective Date: June 26, 2014

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Murale, a division of Shoppers Drug Mart Inc.
243 Consumers Road, Toronto, ON, M2J 4W8
www.murale.ca
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