PRIVACY NOTICE 

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 customers of the McKesson SPS Pharmacy, and visitors of the McKesson SPS Pharmacy website about the purposes for which we may collect, use, and share personal information (collectively referred to as the “Services”). Our privacy practices are in compliance with applicable federal and provincial privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

Our detailed External Privacy Policy can be accessed on www.mckesson.ca.

The External Privacy Policy covers our information handling practices, your access rights, correction processes, and contact information of our Privacy Office for submitting your questions or requests.

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.

Consent & Revocation of Consent

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. Your consent may also be implied based on your actions or inactions when we collect, use, or share your personal information. We will seek additional consent if we intend to use your personal information for purposes not outlined in this Privacy Notice or in the specific terms and conditions of any Service you have agreed to. You may withdraw your consent at any time, though certain limitations may apply based on legal, regulatory, or contractual obligations and reasonable notice; however, without such consent, we may not be able to provide you with certain Services. We may also be entitled by law to contact you for commercial purposes, subject to your right to withdraw consent detailed below.

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, updating your communication preferences through the Services, where applicable, or by contacting your pharmacy directly. Please note that if you opt-out of promotional communications, we may still need to contact you with important information, such as essential updates about your health services, 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 contacting your pharmacy directly or by contacting us at any time using the Contact Information listed in the Contact section below.

Personal Information We Collect

When you use the Services, we may collect personal information about you. The personal information we collect includes: 

• Personal identifiers, including your name, gender, date of birth, contact information, such as email address, telephone number, and physical addresses (postal, shipping, and billing), and demographic information such as city and province/territory.
• Medical information, such as health conditions, diagnosis, prescriptions, medication history and purchases, lab results, and details of any adverse reactions you suffered, including the product causing the reaction, your use of it, other medicines you are/were taking at the time, treatment received, and other relevant medical history for managing and processing adverse event, medical inquiry, or quality complaint reports on our products.
• Health plan and insurance details, such as payer information, benefits eligibility, insurance details, benefit information, claim history, and other payment-related data necessary to process transactions and determine coverage and benefits eligibility.
• Credit and other financial information for those individuals who do business with or obtain services from us, such as billing information, payment method, transaction history, purchase records, account balances, and payment processing data.
• Communication information, such as phone/email correspondence, voice recordings of calls with individuals who contact us or whom we contact, and telepharmacy session recordings where applicable.
• 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
• 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:

• Directly from you: This includes information you provide when enrolling in or using our Services, interacting with us (e.g., via email, text messages, websites, mobile applications, social media, or online advertising), purchasing products, or participating in surveys, promotions, or contests. You may also provide personal information verbally or through self-reported entries, such as medical documents or health-related data (e.g., allergy information, health conditions, height, weight, prescription and medical history, or the type of healthcare service received). Where applicable, the Services may allow you to self-report this information directly.
• From your healthcare provider(s): We may collect personal health information from your healthcare provider(s), medical records systems, or pharmacy management and dispensation software. This may include information such as medication purchases, the name and contact information of prescribing or referring healthcare providers, and any authorized agents acting on your behalf (e.g., caregivers). In some cases, personal information may be collected or generated by your pharmacist or healthcare provider. When necessary, our healthcare providers may contact your physician or others within your circle of care to obtain relevant information.
• In connection with adverse events, medical inquiries, or quality complaints: Personal information may be collected directly from you or from your healthcare provider, depending on who reports the issue, for the purposes identified in this notice.
• Through your electronic activity: We collect information through technologies such as cookies, web beacons, data management platforms, and analytics tools. This may include your IP address, browser type, device identifiers, and interactions with our websites and mobile applications.
• From other sources: We may receive personal information from third parties who represent they have the right to disclose such information, or where permitted or required by law. This may include verifying or updating your contact information (e.g., name, date of birth, home address, phone number) to ensure accuracy and prevent fraud.

How Your Personal Information is Used

We use your personal information for:

• Treatment and care coordination, which includes operating pharmacy services, partnering with healthcare providers and nurses, providing you with information about your prescriptions and healthcare, dispensing and delivering medications, consulting with prescribers, and providing adherence support. This may involve contacting you with appointments, order or refill reminders, information about treatment options, information about financial assistance including benefits navigation, potential side effects and drug interactions, and details on health-related benefits and services.

• Payment and reimbursement, such as billing you or your insurer or health plan for the equipment and services we provide to you. This includes receiving payment for our services or premiums for your coverage, managing your account, fulfilling our responsibilities under your benefit plan, and processing your claims for drugs you have received.
• Healthcare operations to manage our healthcare business. This includes overseeing service quality, offering customer support, handling complaints, monitoring and investigating incidents, managing claims, and managing care-related tasks such as transferring personal information to another pharmacy that provides care to you upon request. We maintain and manage your patient record, including medications dispensed and services or treatments provided. Personal information may be transferred or received during the acquisition or sale of pharmacy locations. We may contact you about health-related products or services, reminders for medication-related actions, recommend programs or events to manage your healthcare needs, and provide notifications about government policies affecting prescription coverage. Your information may be used to comply with healthcare-related professional, legal, and regulatory obligations in accordance with applicable laws. We may link and connect your patient record and data across McKesson Canada related or affiliated entities and service providers to improve the quality of care you receive, effectively manage your care, provide quality service, and enhance our service offerings.
• Regulatory compliance and reporting, which includes managing and processing adverse event reports, handling medical inquiry requests, responding to quality complaints, fulfilling quality control requirements related to product safety, and performing our obligations in accordance with applicable healthcare-related professional, legal, and regulatory requirements.
• Service management, through the use of cookies or other similar technologies to manage the use of our Services and information technology applications or systems, such as for investigating security incidents. For example, we may collect IP addresses to determine Services usage levels, identify, and resolve server issues. We may collect your device’s location to locate a pharmacy nearby you upon your request, and to resolve technical support issues. Location data used for troubleshooting is de-identified, with potential re-identification for escalated technical matters. We may ask you if you want to give our website access to your mobile device’s location. If you grant access to your mobile location, we may collect location data from your device for analytics and to better provide Services to you.

• Marketing and Advertising: Your personal information may be used to support and improve our marketing and advertising initiatives, such as delivering newsletters and facilitating your participation in surveys. This involves delivering advertisements through our platform and third-party web advertisers who may use cookies, tracking advertisement viewing and interactions to advertise products or services that may be of interest to you, and to evaluate marketing effectiveness and service delivery. Please note that third-party advertiser privacy practices are governed by their respective privacy policies, please consult third-party advertisers’ privacy policies for their practices. If you opt to receive marketing communications from us, we will keep you up to date on our products and services. You may withdraw your consent to receiving marketing communications at any time by following the opt-out instructions in each communication, or by contacting us as indicated in the Contact section below.

• Market research and analytics: We may collect and process data to support our market research and analytics activities, including market trend analysis, brand performance evaluation, competitive intelligence, transaction pattern analysis (such as dispensing and adjudication benchmarking), customer behavior insights, market dynamics, and the development and optimization of products and services. This also includes measuring the effectiveness of marketing initiatives. The information we collect, which may be combined with information we receive from other sources about you or other individuals, may be used to analyze purchase history (including transaction types, locations, product details, timing, and promotional activity), and assess program and service utilization. Where authorized or required by applicable law, this data may also be incorporated into commercial analytics products offered to third parties, such as pharmaceutical manufacturers. All such data is either aggregated or de-identified in accordance with applicable privacy laws and our Privacy Policies. We implement robust safeguards to prevent re-identification and ensure compliance with privacy regulations.

Cookies, Web Beacons, and Related Technologies

When you access the Services, 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, where applicable, so that you don't have to re-enter the information each time you use our Services;
• improve your online experience with our Services as well as to provide you with a better personalized advertisements on our Services and on third party websites;
• analyze your usage of our Services and measure trends;
• improve your user experience with the Services;
• measure effectiveness of advertising; and
• help troubleshoot any errors, assist you with your questions, and 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.

You can prevent your computer from accepting new cookies. 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.

When you use 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.

With Whom Do We Share Your Information

Only with your prior, informed consent do we disclose your personal information to others, unless otherwise permitted or required by applicable law. We partner with service providers to support the delivery and improvement of our services, including technology vendors, business consultants, and healthcare service providers. These partners assist us in operating our systems, maintain infrastructure, and enhancing service quality. All service providers are contractually obligated to safeguard your personal information and may only access and use it as necessary to perform services on our behalf. All data processing is conducted in accordance with applicable privacy laws and our strict internal data protection standards.

We may disclose your personal information only as permitted or required under applicable privacy laws, and in accordance with your consent where required. Specifically, we may share your personal information with the following categories of recipients:

• Legal and regulatory authorities, where required to comply with applicable laws, regulations, subpoenas, or similar legal processes;
• Public safety or fraud prevention authorities, when we believe in good faith that disclosure is necessary to protect your health and safety or that of others, to investigate fraud, or to respond to a lawful request by a government authority;
• Successors or assigns, in connection with a merger, acquisition, financing, or sale of all or a portion of our business assets, provided that the recipient agrees to honor our privacy commitments;
• McKesson Canada affiliates and services providers, with your prior consent, for purposes such as improving the quality of care you receive, managing your care effectively, providing quality service, and enhancing our service offerings.

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.

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 to other Canadian provinces outside your province of residence and/or to countries outside of Canada), 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 will strive to protect personal information disclosed to third parties with contractual protections to ensure that service providers with whom we share Personal Information maintain adequate privacy protections and standards. For more details, please visit our External Privacy Policy on www.mckesson.ca.

Access Rights

You have the right to request access to or correction to the personal information we maintain about you.

Please contact your selected McKesson SPS Pharmacy to request access to, correct or delete any personal information that you have provided to the pharmacy. Alternatively, access requests may be made using our online request form .

You can contact us directly any time at the address listed in the Contact section below for any type of request regarding the information you know or believe we hold about you.

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

For inquiries about your personal information or to access, correct, or update your personal information, please contact your designated McKesson SPS Pharmacy directly, as listed on your prescription label.

Privacy Office Contact

McKesson Canada is committed to protecting your personal privacy. If you have questions or comments about this Privacy Notice, 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.