Privacy

BE WELL PROGRAM PRIVACY POLICY

LAST UPDATE: July, 2020

PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT APPLIES TO OUR BE WELL PROGRAM, WHICH HAS TWO COMPONENTS: THE LOYALTY PROGRAM AND PHARMACY SERVICES. THE BE WELL PROGRAM HAS A SINGLE SIGN-UP PROCESS. AFTER YOU SIGN UP, YOU MAY CHOOSE WHICH COMPONENT(S) OF THE BE WELL PROGRAM YOU WISH TO USE: THE LOYALTY PROGRAM, PHARMACY SERVICES, OR BOTH.THE PHARMACY SERVICES PROGRAM WILL ONLY BE AVAILABLE TO THOSE WHO REGISTER USING THE BE WELL MOBILE APPLICATION OR WEBSITE APPLICATION.

 

BY SIGNING UP FOR THE BE WELL PROGRAM, YOU UNDERSTAND THAT THE PROGRAM WILL COLLECT AND USE YOUR PERSONAL INFORMATION (INCLUDING DEMOGRAPHIC AND PERSONAL TRANSACTION INFORMATION) AND, IF YOU SIGN UP AS A DIGITAL MEMBER AND CHOOSE TO PROVIDE IT, PERSONAL HEALTH INFORMATION (INCLUDING HEALTHCARE AND PRESCRIPTION INFORMATION) FOR SUCH PURPOSES AS (i) INFORMING YOU ABOUT PRODUCTS/SERVICES THAT MAY BE OF INTEREST TO YOU, AND (ii) PROVIDING YOU WITH RELEVANT REMINDERS, PROMOTIONS, AND HEALTH AND WELLNESS INFORMATION AS WELL AS CUSTOMIZED ADVERTISEMENTS FOR MEDICATIONS, THERAPIES, OR PRODUCTS THAT MAY BE RELEVANT TO YOUR HEALTH CONDITIONS.

 

BY SIGNING UP FOR THE BE WELL PROGRAM, YOU ALSO AGREE TO THE COLLECTION OF YOUR PERSONAL HEALTH INFORMATION, INCLUDING INFORMATION ABOUT YOUR MEDICAL CONDITIONS, FROM THE PHARMACY TO WHICH YOU CONNECT AND FROM ANY OF THE REXALL PHARMACIES AND OTHER PHARMACY BANNERS PARTICIPATING IN THE PROGRAM AT WHICH YOU RECEIVE PHARMACY SERVICES. THIS PERSONAL HEALTH INFORMATION MAY INCLUDE INFORMATION THAT WAS COLLECTED BY THESE PHARMACIES AND PHARMACY BANNERS BEFORE YOU ENROLLED IN THE PROGRAM. YOU ALSO AGREE TO THE COLLECTION OF YOUR PERSONAL HEALTH INFORMATION DIRECTLY FROM PHYSICIANS OR HEALTH CARE PROVIDERS AS AUTHORIZED BY YOU FROM TIME TO TIME.

 

At McKesson Canada Corporation (“McKesson”, “we” or “us”), we value the trust that our members place in us to appropriately use and protect personal information. The Be Well Program (the “Be Well Program” or “Program”) is a program owned and administered by [McKesson], providing services which include the Be Well mobile application (the “App”), the Be Well website application (the “Web App”), the Be Well website (the “Website”), and the Be Well membership card (the “Membership Card”). The App, the Web App, the Website and the Membership Card are collectively referred to as the “Platform”.

The Program has the following two components :

  • a loyalty program that allows you to earn points through the purchase of products from participating retail outlets (“retail participants”) and to redeem those points for cash savings, and which provides you with customized offers and information based on the information collected about you, including demographic, account and personal transaction information (the “Loyalty Program”); and

  • for those who register using the App or Web App (“Digital Members”), a pharmacy access service that provides you with enhanced pharmacy care services, which include services related to connecting you to a pharmacy, viewing your medication record, refilling a prescription, and providing you with customized advertisements for medications, therapies and products that may be relevant to your health condition(s) (“Pharmacy Services”).

You will be required to provide a specific express consent to enroll with the Program. By enrolling with the Program using the App or Web App, you are automatically enrolling with both the Loyalty Program and Pharmacy Services components of the Program. You can always decide which component(s) you wish to use, and, if you wish to use Pharmacy Services, you can always decide which information you provide to us through Pharmacy Services. We encourage you to read this Privacy Policy in full to understand our privacy practices. If you are not a Digital Member, you will not be able to use the Pharmacy Services component of the Program.

Scope

This Privacy Policy applies to the Program and the use of the Platform by members. Accordingly, it applies to McKesson and all of its affiliates and subsidiaries, as well as their websites, mobile applications and banners, to the extent that any of these entities collect, use, disclose, or receive personal information in connection with the operation of the Program and/or the Platform:

  • Rexall Pharmacy Group Ltd. and its affiliates Rexall/Pharma Plus Pharmacies Ltd., Rexall/Pharma Plus Pharmacies (BC) Ltd. and Rexall/Pharma Plus Pharmacies (Sask) Ltd. (“Rexall”);
  • McKesson Canada Corporation (whose banner pharmacies include I.D.A., Guardian);
  • Medicine Shoppe Canada Corporation;
  • Pharmessor Group Corporation (whose banner pharmacies include Remedy’sRx, Uniprix and Proxim);
  • McKesson Specialty Prescription Services Corporation (which owns McKesson Canada’s Well.ca Pharmacy); and
  • Well.ca ULC (which owns and operates the www.well.ca website).

In this Privacy Policy, McKesson and its affiliates and subsidiaries, including Rexall, are referred to as the “McKesson Group”. The Program also includes the participation of certain additional pharmacy banners in the Loyalty Program and/or Pharmacy Services.

This Privacy Policy applies to the Program and Platform exclusively. Different entities in the McKesson Group may have separate websites, sub-domains, software applications, and services through other web, mobile, or cloud platforms which are unrelated to the Program and that are not subject to this Privacy Policy or which may have their own privacy policies.

Definition of personal information

Throughout this Privacy Policy, we use the term “personal information”, which is any information relating to an identifiable individual. This may include, for example, your contact information, your account information and your health information. It may also include other types of more technical information, but only when this information can identify you as an individual. This Privacy Policy does not cover information that is de-identified and/or aggregated and cannot be associated with an identifiable individual, since this information is not considered to be personal information.

Personal Information We Collect

When you enroll in the Program and use the Platform, we may collect personal information about you. The information we collect may be affected by whether or not you are a Digital Member. The personal information we collect may include, for example:

  • Contact and demographic information, such as your name, gender, date of birth, contact information (postal code, city and province/territory, email address).
  • Account and transaction information, such as your profile picture (optional), password management information and security questions and answers, as well as information related to your participation in the Program (including, for example, the number of points you have accumulated, your history of award redemptions, products that you choose to purchase).
  • Technical information, when this information can identify you as an individual, for instance if it is related to other information you provide. This may include information that you share or make visible on the Internet, including usage information (i.e. your interactions with the Platform, searches and location information), log data (when you access the Platform, our servers automatically receive and log information from your browser), information from your device (hardware model, operating system version, unique device identifiers, location, and available mobile network information), IP address, cookie information, and the pages and functionality requested.
  • Health Information, which may include information about such things as your health conditions, medication purchases, prescription history and underlying diagnosis.

How We Collect Information

We may collect personal information about you in different ways when you participate in the Program (some of the following uses of your personal information are only relevant if you are a Digital Member):

  • From you directly, for instance through your enrolment in the Program; your interactions with us (for example, when you redeem award points or when you communicate with us); your purchase of medications, health products, or other products from participating retailers; or your participation in surveys, marketing promotions, or contests. If you choose to enroll for Pharmacy Services, you may also provide us with personal health information through other means (for instance, verbally to your pharmacist or through a survey).
  • Through your online or electronic activity when using the Platform, whether through the App, WebApp or otherwise, including through self-reported information and communications with us through or with respect to the App or WebApp. The App and WebApp allow you to self-report your health information (or the health information of sub-users, but only if you have their consent, as required by law).  For example, you can enter medical documents, or health-related information such as number of steps, blood pressure readings, heart rate or allergy information, through the App. In addition, the App may connect to and receive information from other third party/health related devices via Bluetooth connectivity (e.g. wearable technology), for example, if you choose to connect your health device/bracelet to the App to share your heart rate in real time.
  • From the McKesson pharmacy management software should you choose to participate and use Pharmacy Services. In such case, your personal health information such as purchases of medication may be collected or generated by your pharmacist or your healthcare provider(s). When you sign up for the Program, the information about you in the McKesson pharmacy management software will be made available to the Program. This includes information that was collected by the software before you enrolled in the Program. It includes information from any of the Rexall pharmacies and other pharmacy banners participating in the Program, as listed above, at which you fill prescriptions or otherwise receive pharmacy services, including information that was collected before you enrolled in the Program.

How We Use Your Personal Information

Different entities in the McKesson Group, including McKesson affiliates or subsidiaries, use the personal information we collect for the following purposes related to the Program:

  • To operate the Program and manage our business, including to:
    • track and process accumulations of points and redemptions of rewards
    • enable your participation in contests, promotions, surveys and chats
    • understand your preferences, needs, and consumer behaviour and improve your customer experience
    • display and provide relevant and personalized content and advertisements through various channels based on information collected about you, including your demographic, account and personal transaction information; for example, if you often purchase diapers, we may inform you of offers on baby formula.
    • communicate with you and manage your account
    • investigate and manage complaints
    • meet our legal and regulatory obligations
  • To communicate with you, including to:
    • take or verify instructions from you and respond to inquiries
    • communicate changes to policies and procedures that affect you, including this Privacy Policy
    • subject to your right to withdraw consent to receive commercial electronic messages, to offer you the opportunity to voluntarily participate in contests or surveys and to market products and services that may be of interest to you (including products and services offered by third parties or other members of the McKesson Group)
  • To conduct data analytics and market research, including to:

    • better manage and develop our business and operations, including to improve or to develop new products, services, programs, promotions, contests or events

    • better understand our customer base. When doing so, we generally will use non- sensitive information (no health information) and will only use your information in an aggregated format or with direct personal identifiers removed. For example, we may analyze members’ data and determine that a certain household products are sold more prevalently in certain geographic areas, but this information will only be created and shared with third parties on an de-identified and/or aggregated basis

  • If you choose to use Pharmacy Services, to operate Pharmacy Services and to provide you with information about your prescriptions and healthcare, including to:
    • remind you of specific actions you need to take regarding your medications
    • inform you of relevant government policies related to your prescription coverage
    • provide you with health and wellness related information
    • allow you to fill and re-fill prescriptions electronically
    • understand your preferences, needs, and consumer behaviour and improve your customer experience
    • present you with customized information and advertisements for medications, therapies and products that are relevant to your health condition(s). For example, if you have diabetes and there is a new diabetes drug therapy that you may benefit from we may let you know about it.

How We Share Your Personal Information

We share your personal information when this is needed to allow you to participate in the Program and whichever components of the Program you are using (the Loyalty Program, Pharmacy Services, or both).

We may share your personal information only in the ways described in this Privacy Policy:

  • McKesson Group. We may share personal information among different entities in the McKesson Group, including McKesson affiliates or subsidiaries, for the purposes identified in this Privacy Policy.

  • Third party service providers. Personal information may be disclosed to such organizations or individuals whose services are retained by the McKesson Group in connection with the Program, including suppliers, and companies contracted to process and manage transactions, redemption requests, research, analysis and communications, advertising agencies, 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.

  • With third parties, at your request or as permitted or required by law. We may need to share information with companies, organizations, or individuals outside of the McKesson Group if we have a good faith belief that access, use, preservation, or disclosure of that information is reasonably necessary to:

  • meet applicable laws, regulations, legal processes, or enforceable governmental requests
  • enforce applicable terms of service, including investigation of potential violations
  • detect, prevent, or otherwise address fraud, security, or technical issues
  • protect against harm to the rights, property or safety of our members, the McKesson Group, or the public as required and/or permitted by law
  • engage in a merger, acquisition, reorganization, or sale of all or a portion of the McKesson Group’s assets.

Otherwise, we may shared members’ information with third parties, but only to the extent that such information has been properly de-identified and/or is provided on an aggregated basis.

Consent

The Program does not collect, use, or disclose personal information from you for any purposes other than those specified in this Privacy Policy, unless permitted or required by law. Consent may be express or implied. Consent can be “express” through words or by specific acts (such as oral or written consent) or implied by your conduct, where it would be reasonable for us to infer that you have agreed to the collection, use or disclosure of your personal information. Because the Program involves the collection of personal information which may be more sensitive (for example, personal transaction information and health information) and the use of such information to provide you with customized information and advertising relevant to your situation, your express consent will be required when you sign up for the Program.

By signing up for the Program, submitting information to us in connection with the Program, or using the Platform, you are providing your consent to the collection, use and disclosure of your personal information as set out in this Privacy Policy. We may also be entitled by law to contact you for commercial purposes, subject to your right to withdraw consent detailed below.

Right to withdraw consent

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 services relating to the Program.

  • 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 by following the unsubscribe instructions included in these emails, contacting us using the contact information listed in the Contact Information section of this Privacy Policy below, or updating your account preferences through the App or Website. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account and content made available or displayed to you online or via the App or the Web App will remain customized for you.
  • Health information: You can always modify the health information you make available within the App or the Web App by accessing your account and making the relevant changes or by calling the call centre at any time using the Contact Information listed in the Contact Information section of this Privacy Policy below.

Account deletion must be completed through the call centre using the contact information listed in the Contact Information section of this Privacy Policy

Access Rights

You have the right to access and update the personal information we maintain about you. You can do so by updating your account information through the App or Website. You can also contact us directly any time at the address listed in the Contact Information section below for any type of request regarding the information you know or believe we hold about you.

Retention

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, and as detailed in section entitled How We Use Your Personal Information. You cannot be identified from de-identified and/or aggregate information retained or used for these purposes.

Children’s Privacy

This Program is not intended for any member under the age of 14 and we do not knowingly collect personal information from children under the age of 14. We do not allow children under the age of 14 to enroll in the Program.

How We Protect Your Information

As a key provider of services and technology to the healthcare industry, the McKesson Group has implemented programs to address the privacy and security requirements of protecting health information. The McKesson Group has also established appropriate physical, technical, and administrative safeguards to protect the personal information we collect from or about our members. We restrict access to personal information to McKesson Group employees, contractors, and agents who need to know the information to process it for us, and who are subject to confidentiality obligations and only share your information as detailed in the section How We Share Your Personal Information above.

Personal information is usually transmitted in an encrypted form using SSL encryption. Notwithstanding our security safeguards, it is impossible to guarantee 100% security in all circumstances. If you have any questions about security or have reason to believe your interaction with us is no longer secure (for example, you feel the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting McKesson at  1-888-596-5131 or by sending an email to privacyofficer@letsbewell.ca.

Cross-Border Transfer of Personal Information

When you use the Program, your personal information may be transferred to and/or stored in another country where we or our service providers operate, including the United States. By enrolling with the Program and/or using the Platform, 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. McKesson will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections.

Changes to this Privacy Policy

We may periodically update this Privacy Policy to describe new features, products, or services we offer and how it may affect our use of personal information about you and your controls. Since we may change this Privacy Policy, we recommend you check the current version available from time to time at letsbewell.ca. If we make changes to this Privacy Policy, we will update the “Last Update” at the beginning of this Privacy Policy. We will inform you periodically, by means of brochures, correspondence, the App, the Website, or otherwise, of any significant change to this Privacy Policy. We may use one or a combination of these methods.

Contact Information

If you have questions or concerns about this Privacy Policy or about our information handling practices relating to your personal information in connection with the Program, please contact us at: compliance@mckesson.ca 

You may also call us Toll-free at 1-877-378-4100

Or write to us at:


ATTN: Be Well, Privacy Officer

 McKesson Canada | 6355 Viscount Road, Mississauga, Ontario L4V 1W2

 

You also have the right to contact your privacy regulator. For example, if you are an Ontario resident with questions or concerns relating to your health information, you may contact:

Information and Privacy Commissioner of Ontario
2 Bloor Street East,
Suite 1400
Toronto, Ontario
M4W 1A8