PRIVACY AND CONFIDENTIALITY POLICY

(The “Policy”)

1. INTRODUCTION

Your privacy and the protection of your personal information is very important to Services Anipharm Inc. (“Anipharm”, “our”, “we” or “us”), which has developed a mobile application (the “Application”) allowing you to submit requests for pharmaceutical services for processing domestic pet prescriptions (the “Services”).

When you contact us or use the Application to access the Services, Anipharm ensures that effective controls are in place to protect the confidential nature of the personal information in its custody.

IMPORTANT - PRACTICE OF PHARMACY:

THE PHARMACEUTICAL SERVICES PRESENTED ON THE APPLICATION ARE OFFERED EXCLUSIVELY BY THE PHARMACISTS OF MAËL ROBERT-LAMARRE PHARMACIEN INC. (THE “PHARMACY”) AFFILIATED WITH ANIPHARM. THEY OFFER THE RELATED SERVICES ONLY ON BEHALF OF MAËL ROBERT-LAMARRE PHARMACIEN INC.

THE PHARMACIST MAËL ROBERT-LAMARRE IS SOLELY RESPONSIBLE FOR THE PRACTICE OF PHARMACY.

2. APPLICATION AND DEFINITIONS

This Policy applies to Anipharm, including its officers, employees, consultants and any person who otherwise provides services for its benefit.

It covers the personal information of customers (potential, current or past).

For the purposes of the present document and as defined by the Act respecting the protection of personal information in the private sector (the “Act”), personal information is any information which relates to a natural person and directly or indirectly allows that person to be identified. For example, it could include a person's first and last name, mailing address, e-mail address, telephone number, gender or banking information, information about your pet or its health, your language and any other personal information you consider useful to provide to us (“Personal Information”). Personal Information does not include an individual's business or professional contact information or personal information which by law is public.

BY PROVIDING PERSONAL INFORMATION THROUGH THE APPLICATION OR BY ANY OTHER MEANS TO ANIPHARM, YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE, RETENTION AND DESTRUCTION OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS POLICY.

3. CONSENT, COLLECTION, USE AND COMMUNICATION

3.1 Consent

Generally, we will obtain Personal Information directly from you, with your consent, subject to exceptions set out in the Act. Personal Information will only be used for the purposes for which it was collected, unless we obtain your consent.

We will not collect, use or disclose Personal Information without your consent unless we are authorized or required to do so under the Act.

Please note that you have the right to refuse to provide us with Personal Information. You also have the right, subject to reasonable notice and applicable legal restrictions, to withdraw your consent to the use of Personal Information already collected by contacting our Privacy Officer at the contact information provided in section 14. Refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide our services or information to you.

IMPORTANT: If you provide us with Personal Information about other individuals, you declare that you have the authority to do so and, if applicable, that you have obtained the necessary consent, and you acknowledge that such information may be used in accordance with this Policy.

3.2 Collection and use

We will only collect your Personal Information if we have a serious and legitimate interest and a valid reason for doing so. The collection will be limited to the information that is necessary to fulfill the purpose.

Below is a list of the information we may collect.

3.2.1 Use of our Application and Services; connection, usage and support data

When you navigate on our Application or use our Services or interact with us via email, we collect information about you as described below, some of which is collected automatically:

• When you use our Application to make an inquiry or other request, we may collect information about you, such as your first and last name, postal address, e-mail address, telephone number, your specific request and information related to your use of the Application.
• When you use our Services, we may collect information about you, such as your first and last name, mailing address, e-mail address, your specific request and information related to your use of the Services, including information about transactions related to the Services. We may also collect information about the pet you have registered on our Application, including its name, age, allergies, gender, breed, veterinarian's name, prescription date and any other necessary information. This information is then transmitted to the Pharmacy.
• When you make a payment to the Pharmacy, we may collect information about you, such as billing and other payment information, including billing name and address, payment method details, such as credit card number or bank account information.
• If you wish to obtain additional information about our Services, register to receive information from us via e-mail, register for an event, webinar or contest, or download certain content, we may ask you to provide us with your contact information, such as your name, telephone number, postal address and e-mail address, as well as certain information about your needs or preferences.
• General location information, such as your IP address and the region in which you are located when you connect to the Application.
• Customer support questions, problems and general comments you choose to provide.
• Any other Personal Information provided.
• Any other Personal Information provided via the Application and to be given to the Pharmacy.

3.2.2 Surveys, events and marketing information

If you choose to participate in our surveys, contests, events, information requests, we may collect information about you in connection with the survey, contest, information request or event; your contact information, such as your name, e-mail address, telephone number; and general information about you that you choose to provide.

3.2.3 Telephone calls

If you communicate with us by telephone, we may record that call and ask you to provide us with contact information, such as your name, address, telephone number, e-mail address, billing information and other payment information.

Any other Personal Information provided.

3.3 Communication

Anipharm limits the communication and disclosure of your Personal Information to the purposes identified above, but note the following clarifications and exceptions:

3.3.1 Application of the law

We may share your Personal Information in accordance with the Act to respond to law enforcement requests, court orders or other legal process or if we believe that such disclosure is necessary to investigate, prevent or respond to illegal activities, fraud, physical threats or as required by any other applicable law or regulation and to the extent necessary to protect Anipharm's property, interests and rights.

3.3.2 Archive service

We may share your Personal Information with a company engaged in the business of preserving documents for their general informational value.

3.3.3 Our employees and authorized service providers

Our employees may have access to your Personal Information in order to help us provide services to you. They access and use such Personal Information in accordance with our instructions, only on a need-to-know basis, and under strict confidentiality and security obligations. Please be assured that our employees manage this information with the necessary discretion and rigor and comply with this Policy and applicable legal and regulatory requirements.

When you provide us with Personal Information, you grant us the right to share your Personal Information with authorized service providers acceptable to us who will use this information to assist us in responding to your requests and performing services. Please note that we will only share the Personal Information necessary to use these third-party services, only for the purpose of providing the services to you, and that we will ensure that these authorized service providers agree to keep this information confidential and secure.

Service providers retain the information they need to perform the functions for which they have been appointed and we do not authorize these third parties to use or disclose your Personal Information for their own marketing or other purposes.

Without limiting the generality of the foregoing, you recognize that by using the Application and transmitting requests for services via the Application, your Personal Information necessary to render pharmaceutical services will be disclosed and communicated to the Pharmacy, including its authorized employees and officers.

3.3.4 Commercial transactions

We may be involved in (1) the sale or lease of all or substantially all of our business and/or assets, (2) the modification of our legal structure by merger or otherwise, (3) a transaction to obtain a loan or other form of financing, and (4) any other similar transaction (individually and collectively the “Transaction”). As part of such Transaction, we may transfer or disclose your Personal Information to the counterparty organization, actual or potential, but we will require such organization to agree to protect the confidentiality of your Personal Information in a manner equivalent to this Policy.

3.3.5 Explicit consent

We may also reveal your Personal Information if you expressly request or consent to such disclosure.

4. YOUR PERSONAL INFORMATION AND THIRD-PARTY WEBSITES

Our Application may contain links to independent third-party websites. These third-party sites (“Third-Party Sites”), whose links are provided solely for your convenience, are not under our control and may be governed by their own privacy policies. We do not warrant and are not responsible for the collection, use, retention or disclosure of your Personal Information by Third-Party Sites. We assume no responsibility for your use of such Third-Party Sites or your access to Third-Party Sites through our Site. By using our Application, or by accessing Third-Party Sites through our Application, you release us from any and all liability for the actions, practices and omissions of such third parties.

5. TRANSFER OF PERSONAL INFORMATION TO FOREIGN COUNTRIES

We strive to keep your Personal Information in Quebec. However, in the future, we may engage third-party service providers to process, manage and host Personal Information on our behalf that may be located outside Canada. As a result, some of your Personal Information may be transferred to another province or country and may be subject to the laws of that province or country.

However, we take care to protect the Personal Information in our custody, including Personal Information entrusted to a service provider, whether located in Canada or elsewhere. Our policies and practices regarding the protection of Personal Information require that a written undertaking be signed by the service provider to respect its obligation to preserve the confidentiality and security of the Personal Information entrusted to it. This includes implementing robust and effective security measures, as well as prohibiting the disclosure of your Personal Information to third parties in accordance with the applicable privacy legislation in the province of Quebec.

6. PROTECTION OF PERSONAL INFORMATION

We take appropriate measures to ensure the confidentiality of Personal Information and to protect such Personal Information against loss, as well as unauthorized access, disclosure, copying, use or modification, taking into account, in particular, the sensitivity of the information and the purposes for which it is to be used.

We use physical procedures, electronic and management procedures and generally accepted industry standards to safeguard and secure the Personal Information we collect.

Furthermore, the Personal Information we hold is therefore only accessible to persons who are entitled to know about it and who consult it only when necessary for the performance of their duties.

For this purpose, we restrict access to our offices and computer equipment, train our staff and require our agents and suppliers of goods and services with access to Personal Information to sign confidentiality agreements and implement equivalent security measures.

Please note, however, that since no mechanism offers maximum security, using the Internet to transmit, create or host Personal Information always involves a certain amount of risk.

If you feel that your Personal Information has been compromised, we invite you to contact our Privacy Officer at the coordinates appearing in section 14 of this Policy.

7. MINORS

Anipharm does not deliberately collect Personal Information from anyone under the age of 18.

If a minor under the age of 14 wishes to use our Application, Services or otherwise contact us, we will not collect Personal Information from that minor without the consent of the parent or tutor. If we become aware that we have unintentionally collected Personal Information from persons under the age of 14 without the consent of the parent or tutor, we will ensure that such information is deleted from our records as soon as possible. If you are the parent or tutor of a minor under the age of 14 and you are aware that your minor child has provided us with Personal Information, we invite you to contact our Privacy Officer at the coordinates appearing in section 14 of this Policy so that we may take the necessary action.

8. RETENTION PERIOD

Anipharm will host and retain your Personal Information for as long as is necessary for the purposes set out in this Policy and to ensure that we comply with our legal and regulatory obligations. You may at any time withdraw or change your consent to our use of your Personal Information, or request that we permanently delete it, subject to any conditions imposed by law.

If you wish to learn more about how long we keep your Personal Information, we invite you to contact our Privacy Officer, whose contact information appears in section 14 of this Policy.

9. ACCESS, RECTIFICATION, UPDATING OF PERSONAL INFORMATION AND WITHDRAWAL OF CONSENT

You have the right to access and obtain copies of your Personal Information. You also have the right to update, rectify and modify any Personal Information that you believe is inaccurate or incomplete. You may also request that we cease disseminating Personal Information about you, or that we de-index any hyperlink attached to your name that allows access to such Personal Information by any technological means, where its dissemination contravenes the Act or a court order. You may do the same, or demand that the hyperlink providing access to the Personal Information be re-indexed, if certain conditions set out in the Act are met.

To do so, please submit a written request to this effect by writing to the Privacy Officer at the address indicated in section 14, who will respond to you in writing within 30 days of the date of receipt of any such request.

If you wish to obtain copies of your Personal Information, we may charge you a nominal fee, which will be disclosed to you in advance, simply to cover the cost of transcription, reproduction and/or transmission.

Subject to legal and contractual restrictions, if any, you may at any time withdraw your consent to the use or disclosure of Personal Information collected about you.

10. ELECTRONIC COMMUNICATIONS (E-MAILS)

Your e-mail address may be used to send you electronic communications from time to time. At any time, you may ask us to stop sending you electronic communications by contacting Anipharm's Privacy Officer at the contact information provided in Section 14 of this Policy or by using the “unsubscribe” instructions provided at the bottom of such communications, if any.

11. AMENDMENTS TO THIS POLICY

Anipharm reserves the right to make changes to this Policy at any time. Such changes will be posted on the Site and will be effective immediately upon posting. We will take reasonable steps, if necessary, to notify users of the Application and our services of any material changes. When we make changes to this Policy, we will revise the “last updated” date at the beginning of this Policy.

You may contact our Privacy Officer at the address or numbers listed in section 14 of this Policy to obtain an up-to-date copy of the Policy.

12. TERMS AND CONDITIONS OF USE OF THE SITE AND SERVICES

The terms and conditions of use of the Application and Services available at www.anipharm.ca contain important provisions disclaiming and excluding the liability of Anipharm and others with regards to your use of the Application and Services, as well as provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute regarding your use of the Application and Services. Each of these provisions also applies to any dispute that may arise in connection with this Policy and the collection, use, retention and disclosure of your Personal Information, and shall have the same force and effect as if they had been reproduced verbatim in this Policy.

13. COMPLAINTS HANDLING PROCESS

13.1 Reception

Any complaint regarding the application of this Policy must be made in writing to Anipharm's Privacy Officer at the e-mail address indicated in the following section.

The complaint must contain the complainant's name, contact information, including a telephone number, as well as the subject of the complaint and the reasons for the complaint in sufficient detail to allow Anipharm to evaluate the complaint. The Privacy Officer may request any additional information deemed necessary to assess the complaint.

13.2 Processing

Please note that Anipharm undertakes to treat all complaints received as confidential and to obtain the advice and recommendations of our advisors. Once the complaint has been received, along with all additional information deemed necessary and requested by the Privacy Officer, Anipharm will have thirty (30) days to analyze it. Upon completion of its analysis, the Privacy Officer will provide the complainant with a written response explaining the reasons for accepting or rejecting the complaint.

Anipharm undertakes to make every reasonable effort to deal with each complaint within thirty (30) days. However, in the event that the complaint cannot be processed within this period, the complainant will be informed of the reasons justifying the extension, the progress made in processing the complaint and the reasonable time required to provide a definitive response.

A separate file will be created for each complaint received, if applicable. The file should contain the complaint, the analysis and documentation supporting its evaluation, as well as the response sent to the person who initiated the complaint.

You may also file a complaint in writing to the Commission d'accès à l'information - Direction de la surveillance at the following address: 900-2045 Stanley Street, Montréal, Québec, H3A 2V4 or by e-mail at cai.communications@cai.gouv.qc.ca. However, we invite all interested parties to first contact the Privacy Officer and to wait until Anipharm has completed its complaint handling process.

14. QUESTIONS, COMMENTS, COMPLAINTS AND PRIVACY OFFICER

Anipharm is responsible for Personal Information in its custody or control and has designated a person in charge who must ensure Anipharm's compliance with this Policy and applicable laws.

If you have any questions, comments, concerns or complaints regarding this Policy and Anipharm's privacy practices, we invite you to contact our Privacy Officer at the following coordinates:
‍

SERVICES ANIPHARM INC.
‍Privacy Officer
2010 René-Lévesque Boulevard
Verdun (Québec)
H3E 2A4
‍info@anipharm.ca

List of versions and changes

Version Effective as of:
1.0 September 18, 2024