Proxim App - Privacy Notice
LAST UPDATED: May 2024
At McKesson Canada Corporation (“McKesson Canada”, “we” or “us”), we value the trust that you place in us to appropriately use and protect your personal information. This Privacy Notice informs visitors and regular users of the Proxim website (www.groupeproxim.ca), the Proxim mobile application and the Proxim web application (https://app.groupeproxim.ca/) who access our health and wellness offerings (collectively referred to as the “Services”) about the purposes for which we may collect, use, and share their personal information. Our privacy philosophy is based on the 10 fair information principles found in the Personal Information Protection and Electronic Documents Act (PIPEDA). We want you to be clear on how we process personal information and the ways in which we protect it.
Our detailed External Privacy Policy can be accessed on www.mckesson.ca.
The External Privacy Policy and this Privacy Notice together are the “Privacy Policies”. We encourage you to read the Privacy Policies in full to understand our privacy practices before using the Services or submitting any personal information.
Because the Services involve the collection of personal information which may be more sensitive (for example, health information) and the use of such information to provide you with prescription management services, customized information and advertising relevant to your situation, your express consent will be required when you register for the Services. If you do not agree with our practices, do not use the Services, and do not download, register with or use any related applications. By using the Services, you agree to the Privacy Policies, and consent to our use and disclosure of your personal information as described herein.
Consent & Revocation of Consent
By using the Services, you understand that we may collect and use your personal information (including demographic, healthcare and prescription information) for such purposes as (i) submitting and managing prescriptions with a Proxim-affiliated pharmacy; (ii) locating your closest Proxim-affiliated pharmacy; (iii) informing you about products or services that may be of interest to you, and (iv) providing you with relevant reminders, promotions, and health and wellness information as well as customized advertisements, Service features or products that may be relevant to you, such as, locating your closest Proxim banner pharmacy, participating in our loyalty programs and accessing the digital flyer of your Proxim-affiliated pharmacy.
By submitting information to us in connection with the Services or using the Services, you are providing your consent to the collection, use and disclosure of your personal information as set out in this Privacy Notice and we, as well as our staff, may rely on that consent. We may also be entitled by law to contact you for commercial purposes, subject to your right to withdraw consent detailed below.
Consent may be withdrawn at any time, subject to legal, regulatory, or contractual restrictions and reasonable notice; however, without such consent, we may not be able to provide you with the Services.
Careers page: By accessing the careers page, you will be redirected to a website hosted by a third party. Please be aware that McKesson Canada is not responsible for the way in which you interact with this website or submit your information for job opportunities. If you have any questions regarding your privacy rights in relation to your candidate information, please contact the pharmacy to which you have submitted your application to.
Commercial Electronic Communications: You can always limit the communications that we send to you. You may choose to stop receiving our newsletter or marketing emails, if applicable, by following the unsubscribe instructions included in these emails, contacting us using the contact information listed in the Contact section of this Privacy Notice below, or updating your account preferences through the Services. Please note that if you opt-out of commercial communications, we may still need to contact you with important information about your account, and content made available or displayed to you via the Services will remain customized for you.
Health information: You can always modify the health information you make available within the Services by accessing your account and making the relevant changes or by calling the call center at any time using the Contact information listed below.
Account deletion can be completed through both the Proxim mobile and web applications by accessing your account settings and clicking on “Delete account”. If using the Proxim mobile application, you may also discontinue information collection by uninstalling the Proxim mobile application using the standard uninstall processes available through your mobile device, the mobile application marketplace or network.
Personal Information We Collect
When you use the Services, we may collect the following personal information about you:
- Contact and demographic information, such as your name, gender, date of birth, contact information (postal code, city and province/territory, email address, home/shipping address, telephone number).
- Account and transaction information, such as your password management information and security questions and answers, as well as information related to your participation in the Services (including, for example, products that you choose to purchase).
- Technical information, such as log and usage data when you access or use our Services. This data includes service-related, diagnostic, usage, and performance information, which we record in log files. Depending on your interaction with us, this log data may contain your IP address, device information, browser type and settings, details about your activity on our Services (such as timestamps, viewed pages and files, searches, and feature usage), as well as device event information such as system activity, error reports and hardware settings.
- Health information may include information about your health conditions, medication purchases, prescription and order history, underlying diagnosis and registration information.
- Location information, which can be precise or imprecise, depending on how you interact with our Services and your device’s settings. This data includes information about your current location, obtained through GPS and other technologies based on your IP address. You have the option to refuse access or disable the location setting on your device to opt out. However, please note that opting out may restrict your use of certain Services.
How Your Personal Information Is Collected
We may collect personal information about you in different ways when you use the Services:
- From you directly or your authorized representative, for instance through your enrolment in, or use of, the Services; your interactions with us (for example, when you interact with our Services, email, newsletter, social media accounts and online advertising); your purchase of products from us or participating retailers; or your participation in surveys, promotions, or contests. You may also provide us with personal information through other means (for instance, verbally).
- Through your online interactions with us and your electronic activity when using the Services; including through the use of technologies, such as cookies, web beacons, data management and advertising platforms, and self-reported information and communications with us through or with respect to the Services. For example, your IP address is reported by your web browser whenever you visit a page on the internet. Whenever a user visits our Services, their IP address, along with the time of the visit and the pages accessed, is automatically recorded in our server log files.
- In some cases, information may be collected from third parties who represent they have the right to disclose such information to us, for example, your authorized representative, your healthcare provider or pharmacist, either directly or through a medical records system or pharmacy dispensation software.
How Your Personal Information is Used
We use your personal information to provide you with our products and Services, which include:
- Creating, administering and maintaining your account;
- When you choose to use the Proxim mobile application to manage your health and prescriptions, we may use your personal information to:
- Provide prescription management services like filling and refilling prescriptions electronically, dispensing your medications, and to provide you with information about such services;
- Remind you of specific actions you need to take regarding your medication, such as refilling prescriptions, provide you with health and wellness information and information about other related services;
- Manage your patient records, including medication history and the services or treatments you have received;
- Offer additional services such as a list of prescriptions for tax purposes or general health assessment for conditions such as diabetes, hypertension, or osteoporosis. Please note that these assessments are for informational purposes only and should not be used for diagnosis or treatment. Always consult a medical health professional for advice about your health; and
- As required to comply with legal and regulatory requirements.
- Manage the use of our Services, and our information technology applications and systems, which may include using cookies and other similar technologies and investigating incidents. For example, we collect IP addresses for determining Services usage levels, identifying and resolving server issues, and managing the Services (including activating your network services to connect to the Proxim applications or your selected pharmacy’s database);
- Enable your participation in surveys, promotions or contests;
- Manage and administer the loyalty program in which you have registered, including tracking your loyalty points, providing personalized offers and rewards, and communicating program updates to enhance your overall experience;
- When you request our Services to locate a store nearby you, we may ask for access to your mobile device’s location. We may also collect your device’s location for troubleshooting purposes when you request technical support. Information collected for troubleshooting purposes is de-identified and may be re-identified upon escalation of the technical matter;
- Communicate with you to respond to your inquiries and provide you with information and updates about our products, services, promotions and contests through the communication method you have consented to. For example, when you sign up to our newsletter, you may receive information about our or third-party products and services and news from your Proxim-affiliated pharmacy. You have the option to unsubscribe from receiving electronic communications at any time by following the instructions provided in each message, or by contacting us as indicated in the Contact section below;
- Deliver advertising related to our or third-party products and services that may be of interest to you. For example, we may suggest promotions or features, such as setting up refill reminders and subscribing to our mobile application. Please note that we will not use sensitive personal information (like health information) for advertising purposes without your express consent. We may analyze your engagement with our or third-party products and services to understand the effectiveness of our marketing campaigns and to deliver customized products and services. This helps us gain insights into consumer behavior and improve our marketing strategies; and
- Conduct market research and analytics to improve our products, services, promotions and contests, to better understand our customer base and to customize our products and services accordingly. For example, we use information such as how many users are subscribed to our Services, website and account activity (e.g., interactions with our services such as offers viewed, use of features and opt-out preferences), promotional offers viewed, and advertisements interacted with. Wherever possible, we process this information in an aggregate, anonymized or de-identified format, with personal identifiers removed so it cannot be linked back to an individual.
Cookies, Web Beacons, and Related Technologies
When you access the Services or register for an account, we may collect certain information using our or third-party technologies such as cookies, web beacons and other similar technologies. Cookies are alphanumeric identifiers that are saved on your computer’s hard drive to enable our systems to recognize your browser between visits and remember, for example, your IP address, log in credentials or products you last searched on our website. Web beacons, also known as tracking pixels or pixel tags, are small image files embedded in a website or email that collect information about users’ online activity, such as pageviews, clicks, and interactions with our emails or ads.
For the purposes of this Privacy Notice, cookies, web beacons, and all other similar technologies are collectively referred to as “cookies”. We use cookies to:
- remember information you gave us so that you don't have to re-enter the information each time you use our Services;
- advertise our products and services on third party websites;
- analyze your usage of our Services and measure trends;
- improve your user experience with the Services;
- measure the effectiveness of advertising; and
- help troubleshoot any errors, assist you with your questions, and improve fraud detection.
We collect information about you through cookies. This information may be combined with other personal information we have about you from our other services. By doing this, we can provide better services and fulfill the purposes outlined in our Privacy Notice.
When you visit the Services, you will see a notice about our use of cookies, providing you with the opportunity to accept all cookies, reject all cookies that are not strictly necessary, or learn more about the types of cookies used and customize your choices. You can also delete or disable cookies at any time via your browser. Most browsers tell you how to do so in their “help” section. Because cookies allow you to take advantage of some of the Service’s features, we recommend you leave them turned on. For instance, if you block certain cookies, it may disable certain functions of the Services.
With Whom Do We Share Your Information
Your personal information may be disclosed to third parties retained by McKesson Canada in connection with the Services, including suppliers, and companies contracted to process and manage transactions, redemption requests, research, analysis and communications, advertising agencies and technology vendors, direct marketing agents, data processing and storage firms as well as mailing houses, and providers of administrative support service. These agents, representatives or organizations must sign a confidentiality agreement which includes data security provisions and may only use the information disclosed to them for the purposes mentioned in the agreement, after which they must return the information to us or destroy the information, without keeping a copy. They are prohibited from disclosing the information to third parties without obtaining appropriate consent in advance.
We may also disclose personal information:
- As required by law, such as to comply with a subpoena or similar legal process;
- When we believe in good faith that disclosure is necessary to protect our rights or property, protect your health and safety or the health and safety of others, investigate fraud or potential violations of our terms of service, or respond to a government request;
- If we are involved in a merger, acquisition or sale of all or a portion of its assets;
- Among McKesson Canada affiliates or subsidiaries for the purposes identified in the Privacy Policies; and
- To any other third party with your prior consent to do so, such as your Proxim-affiliated pharmacy for prescription management services, where applicable, or third-party freight providers where we share your name, phone number, email and shipping address to complete your delivery.
Please note where a link redirects you to another website or application, different terms and conditions, as well as privacy practices, may apply. We encourage you to read the privacy notices of all websites you visit to understand their privacy practices and your options.
How Your Personal Information is Protected
As a key provider of services and technology to the healthcare industry, McKesson Canada has implemented programs to address the privacy and security requirements of protecting health information. For more information about our Data Governance and Security Measures, visit our External Privacy Policy at www.mckesson.ca.
We will retain your personal information to meet our contractual obligations to you and for as long as your account is active or potentially active, is reasonably useful for commercial purposes, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain de-identified and/or aggregate information beyond this time for research purposes and to help us develop and improve our services as stated in this Privacy Notice.
Children’s Privacy
The Services are not directed to children under the age of 14, and we do not knowingly collect information from children under the age of 14 without express consent in accordance with all applicable laws.
Cross Border Transfers
When you use the Services, your personal information may be transferred to and/or stored in another country or province (which may include transfer outside of Quebec), where we or our service providers operate, including the United States. By using the Services, you agree to such cross-border transfer of your personal information and understand that your information may be available to government authorities under lawful orders and laws applicable in foreign jurisdictions. We strive to protect personal information disclosed to third parties with contractual protections to ensure service providers with whom we share personal information with maintain adequate privacy protections and standards. For more information on our data governance and security measures, please visit our External Privacy Policy on www.mckesson.ca.
Your Privacy Rights
You have the right to request access to, correction or deletion of the personal information we maintain about you. Please contact your selected pharmacy (the pharmacy whose name and contact information appears on your prescription label) to request access to, correct or delete any personal information that you have provided to the pharmacy.
In addition, you may also wish to update your personal information that is saved through the Services by accessing your account settings and amending your information accordingly. Please note that changes you make directly to your personal information through the Services may not be automatically transmitted to your selected pharmacy, as such, you will need to notify the pharmacy separately as outlined above.
You can contact us directly any time at the address listed in the Contact section below with any questions or to exercise your privacy rights as described in this Privacy Notice.
Updates to this Notice
We will review this Privacy Notice periodically and will update this to address changes in applicable laws and regulations as necessary. Please check back to ensure you have the most up-to-date Privacy Notice.
Contact
Privacy Office Contact
McKesson Canada is committed to protecting your personal privacy. If you have questions or comments about our efforts to protect your personal privacy, or if you require additional information about our privacy practices, please contact us at compliance@mckesson.ca.
You may also write to our Privacy Officer at: McKesson Canada Corporation, Attn: Privacy Officer, 2300, Meadowvale Blvd., Mississauga, ON, L5N 5P9.