Electronic Privacy Policy

Any patient, agent, or other third party (the “User”) in the course of its dealings with Acre Distribution Inc. (“Acre”) or otherwise, acknowledges that when visiting the Acre web site at http://acredistribution.com/ (the “Website”), or other online resources maintained by Acre, the User may provide personal information and/or personal health information to Acre.

Protecting a User’s privacy is paramount to Acre. To accommodate any concerns with how personal information is protected, Acre has created this policy (the “Electronic Privacy Policy”), which articulates how Acre collects, uses and discloses personal information obtained by Acre when Users are visiting the Website, utilizing the services provided via the Website, as well as information received from electronic mail and other downloadable material.

The Electronic Privacy Policy does not apply to personal information collected from offline resources and communications, except in cases where such personal information is consolidated with personal information collected by Acre. The Electronic Privacy Policy also does not apply to third-party online resources to which the Website may link, where Acre does not control the content or the privacy practices of such resources.

Acre reserves the right to alter or modify the Electronic Privacy Policy from time to time in its sole and absolute discretion. By using the Website, you acknowledge and agree to be bound by the provisions of the Electronic Privacy Policy.

Personal Information is defined in Personal Information Protection and Electronic Documents Act (“PIPEDA”) as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card or information that is available in public records. Personal Information includes, but is not limited to, a User’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, interests, browsing preferences, web logs, Internet protocol addresses, network and server particulars, and/or other information relevant to the Website, promotional and marketing activities.

Personal health information is more specific, and is defined in the Personal Health Information Protection Act, 2004 (Ontario) (“PHIPA”) as identifying information about an individual which relates to that individual’s physical or mental health, the provision of health care to that individual, payments made or eligibility for health care or health care coverage of that individual, organ, tissue and fluid donations made by that individual, that individual’s provincial health card number and the identit(ies) of that individual’s substitute decision-maker(s)

Since January 1, 2004, all Canadian organizations engaged in commercial activities have been required to comply with the PIPEDA and the Canadian Standards Association Model Code for the Protection of Personal Information, incorporated by reference into PIPEDA. These obligations extend to Acre and are integrated into the Electronic Privacy Policy herein.

Moreover, as a pharmacy, Acre is subject to the more stringent obligations imposed by PHIPA to the extent personal health information is collected, used and disclosed. Where these more stringent obligations apply, Acre will abide by these higher standards.

By using the Website, the User consents to the collection, use, and disclosure of the User’s personal information in accordance with this Electronic Privacy Policy.  If the User does not consent to the Electronic Privacy Policy, as set out herein, the User must immediately cease use of the Website. Please note that the User’s access and continued use of the Website will be deemed as consent by Acre.

Any personal information collected or disclosed without the consent of a User will only be collected or disclosed in limited circumstances that are expressly permitted by law. For example, privacy legislation permits the collection or disclosure of personal information in certain circumstances where there is a concern for health and safety, or in an emergency.

A User may withdraw their consent to allow Acre to collect personal information and/or personal health information, however Acre will still be required to maintain certain records with regard to the distribution of medication to comply with provision laws.

If a User withdraws or limits its consent for Acre to collect or disclosure personal information and/or personal health information, Acre may be limited in its ability to provide pharmacy services – as this may limit Acre ability to access essential information, or limit its ability to contact a User’s insurer, physician, guardian etc.

Importantly, this Website is intended for users who are over 18 years of age. Persons who are 18 years of age or less should not provide any personal information or personal health information directly to Acre, and Acre will require a parent or guardian to communicate directly with Acre for all services related to children or minors.

Acre collects Users’ personal information and personal health information in order to enable us to communicate with Users and provide them with our services. Acre collects a User’s Personal Information in one of three ways; unsolicited information provided by a User, information obtained from the public or third parties, and information collected from a User’s computer or other electronic device.

Unsolicited Information

Acre may collect unsolicited personal information and personal health information provided by a User voluntarily, such as data entered into forms or data fields on the Website or via any other online resources.

Information from Public or Third-Parties

Acre may collect personal information and personal health information from Users that register on the Website from public or third party information sources to verify their professional credentials and identity. If names and contact information for a User’s physician and other health practitioners are provided via the Website or via any other online resources, Acre may contact them to collect further information.

Information Collected from a User’s Computer or other Electronic Device

Acre collects information from a User’s computer and other electronic devices when a User accesses the Website and other online resources.  The information that is collected during this process includes but is not limited to a User’s Internet Protocol (IP) address, domain name, browser type, date and time of a User’s request and information provided by tracking technologies, such as cookies and single-pixel tags, which are defined below.

If a User is accessing the Website from a mobile device, Acre may collect information about the User’s device, such as a User’s device ID and device type, as well as usage information, use of mobile websites and other mobile resources.

“Cookies” are small text files placed on a User’s hard drive that assists Acre in providing a customized browsing experience. Cookies contain a unique identification number that identifies a User’s browser, but not the visitor, to Acre’s computers each time a User visits the Website. Acre uses cookies to make navigation of the Website easier for visitors and to facilitate efficient registration procedures.  If a User is concerned about cookies, most browsers permit individual to refuse to accept all cookies or to notify Users when a User has received a cookie.  However, a User should note that if the User refuses to accept cookies, the User may not be able to use some of the features available on the Website and other online resources.

“Single-pixel tags”, also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible.  Single-pixel tags are used to collect information in web logs that do not identify a User personally such as web pages viewed, the web site a User came from and the advertisement the User clicked on to visit the Website.  Single-pixel tags are also used to confirm whether promotional or other commercial e-mail messages that are sent via the Website are opened.

In order to properly manage the Website, Acre may also anonymously use log information on operational systems, and identify categories of Users by items such as domains and browser types. Statistics may be reported to a party assisting Acre in offering the Website, such as webmasters.

Acre only collects personal information and personal health information to the extent that it is necessary to accomplish the specific purposes for which it is being collected.

Acre collects, uses and discloses Personal Information to better understand a User’s needs and to provide a User with better services. In particular, personal information and personal health information is collected for the following reasons:

  • internal record keeping to comply with existing federal and provincial legislation;
  • to identify products, facilitate orders and otherwise provide Acre’s services;
  • to improve services;
  • to audit online resources for authorized access and security;
  • to submit reports to Health Canada;
  • to address possible adverse events, product complaints, special situation reports or medical inquiries; and
  • such other uses as may be permitted or required by applicable law.

Acre may remove identifying data from your personal information and personal health information to be used to assess various factors, including trends in prescriptions, compliance, and health, in order to improve upon our services. Personal information and personal health information from which identifying data has been removed may be shared with third parties for the purposes set out above.

In certain limited circumstances, Acre may be required to release or provide access to personal information or personal health information in response to a subpoena, search warrant, court order, law, or regulation. In such case, Acre will take all appropriate measures to ensure that Users’ personal information and personal health information is protected to the greatest extend possible while Acre cooperates fully with court and law enforcement authorities in this regard.

Personal information and personal health information will be accessible to Acre, and to individuals and organizations that use personal information and personal health information gathered by Acre, solely for and at the direction of Acre. Uses and disclosures of personal information and personal health information by external individuals and organizations acting on Acre’s behalf are governed by agreements that require personal information and personal health information to be protected appropriately. When Acre allows a third party service provider to have access to your personal information, they will only be permitted to take it or use it for purposes that are consistent with this Privacy Policy. Acre’ ability to allow others to access personal health information is further restricted by PHIPA.

User specifically consents to Acre disclosing personal information and personal health information to external individuals and organizations strictly in accordance with this Electronic Privacy Agreement, to inform such external individuals and organizations, where necessary, of possible adverse events, product complaints, special situation reports or medical inquiries, or to assist such external individuals and organizations in investigating responding to, remedying, or preventing future adverse events or complaints.

User specifically consents to Acre, or external individuals and organizations to which Acre may have disclosed personal information and personal health information, using the personal information and personal health information as follows, provided such use is strictly in accordance with this Electronic Privacy Policy:

  1. combining information relating to an individual with other information linked to that individual, for example any reviews or assessments by of that individual’s performance of or interaction with the health services or products, and any information received from third parties such as recruitment agencies;
  2. disclosing information, including personal information and personal health information , as required by any applicable government laws or regulations, and to financial institutions or governmental authorities; and
  3. sharing an individual’s contact details and any reviews or assessments of that individual’s performance of or interaction with health services or products with third parties so that those third parties may contact that individual with a view to entering into agreements with Acre for the provision to them of services similar to the services being provided by Acre.

Unless otherwise advised, Acre will not share personal information or personal health information except as described in the Electronic Privacy Policy and other applicable privacy notices. However, Acre reserves the right to disclose personal information and personal health information, including e-mail addresses, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by law. Except as provided in the Electronic Privacy Policy, personal information and personal health information will not otherwise be shared without a User’s permission.

Acre may communicate with and disclose your personal information or personal health information to persons who Users expressly designate to be involved in their health care or health care decisions, such as a physician, guardian or attorney.

User understands that Acre may disclose personal information or personal health information to external individuals and organizations, strictly in accordance with the terms of this Electronic Privacy Policy, located in countries outside of Canada whose laws provide for less protection for that member’s personal information, the User specifically consents to their personal information being transmitted to any such countries.

User understand that Acre may notify external individuals and organizations if Acre becomes aware of any non-compliance with any privacy laws, including any unauthorized or unlawful collection, use or disclosure of or any accidental loss or destruction of, or damage to personal information or personal health information or of any circumstances that would cause a reasonable data security professional to suspect that such collection, use or disclosure, loss, destruction, damage or non-compliance had occurred or will occur.

Acre may disclose your personal information or personal health information to a buyer or transferee in connection with the sale, assignment, or reorganization of its business, in which case Acre will require any such buyer to agree to treat it in accordance with this the terms of this Privacy Policy.

A User may withdraw their consent to Acre’s collection, use and disclosure of personal information and personal health information at any time, subject to legal and/or contractual restrictions and upon reasonable notice, by contacting Acre’s Privacy Officer. Please note certain personal information and personal health information will be collected automatically when a User visits the Website. A User’s continued use of the Website will be deemed consent to obtain any personal information and personal health information that derives from the User’s use of the Website.

A User may choose not to provide Personal Information to Acre by electing not to enter any Personal Information into a form or data field, and by not using any personalized services provided by the Website or by any other online resources.  However, some of the Website may only be available to Users that provide personal information or request the use of personalized services.

If a User previously agreed to permit the use of Personal Information for marketing or promotional purposes, a User may revoke consent by following the opt-out instructions in each communication or by writing to Acre’s Privacy Officer.

Acre employs physical, administrative, and technological security safeguards appropriate to the sensitivity of the information. With respect to personal health information collected, Acre acts as custodian thereof and takes all precautions required by PHIPA to prevent the unauthorized disclosure thereof.

Acre will take all reasonable and legally required steps to protect personal information and personal health information as it is transmitted from a User’s computer to the Website or other online resources and servers. Acre will also protect personal information and personal health information from unauthorized access, disclosure, alteration or destruction.  Acre ensures that all affiliates and other third parties that are retained to perform services on Acre’s behalf and are provided with personal information and/or personal health information are contractually required to observe the Electronic Privacy Policy. It is a User’s personal responsibility to secure a User’s own copies of any logins, passwords and related access codes used on or for the Website.

Please note, security risks on the internet cannot be eliminated, and Acre cannot and does not guarantee that a User’s personal information and personal health information will not be accessed in ways not otherwise described in the Electronic Privacy Policy.

Users may access, update, and correct personal information in the possession of Acre, subject to certain exceptions prescribed by law.

Upon written request, Acre will provide a User with any personal information and personal health information in its possession to the extent required by law.

If a User would like to access any of its personal information and personal health information, or believes that any of the personal information and personal health information collected by Acre relating to a User is incorrect or incomplete, please send an electronic message to Acre’s Privacy Officer, as provided below.

To comply with existing federal and provincial legislation, and to ensure that we are able to refer to a User’s personal information and personal health information when necessary, Acre keeps records of all prescription medications dispensed. Personal information and personal health information is retained by Acre for minimum time periods required by law. When Personal information and personal health information is no longer required to be maintained, Acre will delete it, or remove personal identifying data from such information.

Former Users

If a User ceases using the Website, or a User’s access to the Website has been terminated, Acre may continue to use and disclose a User’s personal information and personal health information in accordance with the Electronic Privacy Policy.

Terms and Conditions of Use of Website

Any applicable terms & conditions of use governing a User’s use of the Website contain important provisions, including provisions disclaiming, limiting, or excluding the liability of Acre for a User’s use of the Acre Website and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding a User’s use of the Acre Website.  Each of those provisions applies to any disputes that may arise in relation to the Electronic Privacy Policy, including any collection, use and disclosure of personal information and personal health information and are of the same force and effect as if they had been reproduced directly in this Electronic Privacy Policy.

Third Party Links and Web Sites

The Website may contain links to other third party web sites or internet resources, which are not affiliated with the Website, nor provided by Acre, and are not subject to the Electronic Privacy Policy.  The User assumes any risk associated with any third party links or Websites. Acre assumes no responsibility or liability for, or control over any third party Websites or their collection, use and disclosure of a User’s personal information and/or personal health information.

Electronic Privacy Policy Amendments

To accommodate amendments to the Website, changing technology, and legal developments, the Electronic Privacy Policy may be revised in Acre’s absolute discretion and without any prior notice or liability to the User or any other person.  Acre’s collection, use and disclosure of the personal information and personal health information through the Website will be governed by the version of the Electronic Privacy Policy in effect at that time when the information is collected, used, or disclosed.  New versions of the Electronic Privacy Policy will be posted on the Website and will be available upon request from Acre.  A User’s continued access, use and/or dealings with the Website after any amendments to the Electronic Privacy Policy, will signify a User’s consent or continued consent to the collection, use and disclosure of personal information and personal health information in accordance with the revised Electronic Privacy Policy. 

For More Information

For more information about the Electronic Privacy Policy, please contact the Acre Privacy Officer, via electronic mail or write to us at:

Attn: Privacy Officer
Acre Distributions Inc.
3-250 Shields Court
Markham, ON L3R 9W7

For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:

Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3

Or your provincial office of the Information and Privacy Commissioner for more information.