Privacy Policy

General Privacy Policy

Is committed to maintaining the privacy of individuals and protecting personal information in its control in accordance with privacy legislation applicable to Paragon.

This Policy describes and summarizes the practices of Paragon with respect to our collection, use and disclosure of personal information related to individuals other than employees of Paragon. For information related to the policies of Paragon with respect to its employees, Paragon maintains and follows a separate Employee Privacy Policy, which may be requested from the Privacy Officer of Paragon.

Among other things, this Policy describes the obligations and practices of Paragon under the Personal Information Protection Act (British Columbia), Personal Information Protection Act (Alberta) and the Personal Information Protection and Electronic Documents Act (Canada, "PIPEDA"), as applicable.

Paragon does not sell, lease or rent your personal information to any third party and will only disclose personal information as stated in this Policy or as required by law. This Policy may be changed or modified at any time. All such changes will be posted on the Paragon website at www.paragonpharmacies.com and become effective upon posting.

Definitions

In this Policy, the following terms have the meanings below:

· Personal information means information about an identifiable individual, which does not include information of an aggregate or anonymous nature where a specific individual or individuals cannot be identified. Personal Information also does not include business contact information, or work product information.

· Business contact information means information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual.

· Work product information means information prepared or collected by an individual or group of individuals as a part of the individual/'s or group/'s responsibilities or activities related to the individual/'s or group/'s employment or business but does not include personal information about an individual who did not prepare or collect the personal information.

Privacy and our Website

Paragon respects your privacy and we are committed to providing you with a secure and confidential experience on our website.

We do not collect any personal information from you when you simply visit our website. However, you should be aware that most web servers do collect some information about visitors, such as the browser and version you are using, your operating system, and your "IP" or internet address, which may identify your Internet Service Provider and, if your Internet Service Provider agrees to do so, your computer but generally not the individual using it.

It is our policy to only collect personal information with consent unless otherwise required or permitted by law. If you voluntarily submit personal information to us by email or via our website for specific purposes, such as obtaining information or subscribing to our newsletter, we will consider that you have done so with your consent for purposes reasonably related to your providing the information. After our initial response, we will communicate further with you with information about market offerings, products and services that may be useful or of interest to you, but we will include instructions on how to terminate receiving such further information. You may opt out at any time.

Specifically, Paragon collects personal information related to our E-Fill service and newsletter section. Information collected for those purposes is used to respond to you and provide you with requested information, as well as the information mentioned above.

Please be advised that the Internet and email are inherently insecure media. While we use Secure Sockets Layer (SSL) technology to protect information transmitted to us via our website, we cannot take responsibility for the security or privacy of personal information in transit over the Internet.

Please also note that our website may contain links to other websites which are provided as a convenience for visitors to our website only. Any third party websites will have their own privacy policies and practices, and we cannot be responsible for such third parties or their websites.

We consider resumes, job applications, and similar communications submitted through our Website or otherwise to be personal employee information about you as a prospective employee and to be governed by our Employee Privacy Policy. Resumes and job applications are used by us to evaluate and consider applicants for employment, and we may collect and use personal information about the applicant without notification or consent to the extent permitted by law for the purposes of considering whether or not to enter into an employment relationship.

Prescriptions

Paragon will collect, use and disclose your personal information to process a prescription refill request. All required fields in our online prescription refill form are necessary to properly identify the patient and the prescription and to obtain payment for the same. The receipt of a refill request by a pharmacy will be deemed an implicit consent to the collection, disclosure and use of your personal information for the safe processing of the prescription. This may include Paragon/'s contacting your physician (or other prescribing professional) to discuss the refill request, your medical condition(s) and medication history and collect further information to be used and disclosed by Paragon for the purposes of filling and refilling prescriptions. In addition, information about your prescription may be transmitted for payment processing through your health plan or insurance or to otherwise obtain payment, such as from your credit card company. Your consent to this disclosure of personal health information is deemed by your request for payment or reimbursement for the prescription pursuant to or by way of such health plan and/or the provision to the pharmacy of the details of your health plan and/or your credit card company.

Sources of Personal Information

Paragon generally collects, uses and discloses personal information about the following types of individuals:

· Employees of Paragon for the purposes of establishing, managing and terminating employment and contractor relationships. Resumes, job applications, and similar communications submitted through our Website or otherwise constitute personal employee information about a prospective employee and will be governed by our Employee Privacy Policy, a copy of which is available on request to prospective, current and past employees.

· Shareholders and investors in Paragon;

· Directors of Paragon;

· Individual suppliers and contractors to Paragon

· Customers and clients of Paragon, including patients with respect to prescriptions and related services;

· Subscribers to newsletters and other publications; and

· Other individuals who may voluntarily choose to provide Paragon with personal information.

Notification and Consent

Subject to this Policy and applicable legislation, Paragon will identify the purposes for collection, use and disclosure in advance of collection, and will notify the individual of the purposes for collection, use or disclosure at or before the time of collection.

There are a number of exceptions to the above provisions in that in some circumstances, such as certain personal information related to employees, in which case Paragon does not require consent to collect, use or disclose personal information but is generally required to provide notification in advance.

In other circumstances, specifically those set out in applicable legislation, the law does not require that Paragon obtain consent or provide notification. Paragon reserves all its rights to rely on any and all available statutory exemptions and exceptions.

Exceptions to the Requirement for Consent

Generally under privacy law, Paragon may collect, use or disclose personal information without consent in circumstances that include but are not limited to the following:

· The collection use or disclosure is required or authorized by law;

· Where our doing so is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way;

· The disclosure is for the medical treatment of the individual and the individual does not have the legal capacity to provide consent;

· The collection, use or disclosure is for the purpose of contacting the next of kin or a friend of an injured, ill or deceased individual;

· It is reasonable to expect that collection, use or disclosure with the consent of the individual would compromise an investigation or proceeding and the disclosure is reasonable for purposes related to an investigation or a proceeding;

· The personal information is available to the public from a lawful source;

· Where the collection, use or disclosure of the information is pursuant to a statute or regulation of either British Columbia, Alberta (or applicable law of another province) or Canada that authorizes or requires the collection, use or disclosure;

· Where the information is disclosed to another organization solely for the purposes for which the information was collected by consent in the first place in order to allow the other organization to assist Paragon by carrying out work on behalf of Paragon (for example, outsourcing);

· Where the collection, use or disclosure of the information is reasonable for the purposes of an investigation or a legal proceeding;

· Where the collection, use or disclosure of the information is necessary in order to collect a debt owed to Paragon or for Paragon to repay to an individual money owed by Paragon;

· Where information is disclosed to a lawyer representing Paragon; and

· In the context of obtaining credit reports where the individual in question originally consented to their information being available for that purpose.

In addition to the above, the law generally provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information. If you provide personal information to us voluntarily, we will rely on deemed consent and consider that you consent to our collection, use or disclosure of your personal information as necessary to carry out the purposes for which you provided the information.

Paragon will in all cases disclose personal information as required by applicable law, which includes, but is not limited to, the laws related to securities and shareholders in corporations, and directors and officers of corporations, and the rules of any applicable stock exchange.

Where a new purpose for the use or disclosure of personal information previously collected arises, Paragon will contact the individual in question, if required to do so, in order to obtain any required consent or to provide any required notification for use and/or disclosure for such new purpose or purposes.

Where practical, Paragon will try to collect personal information directly from you. Where necessary, Paragon will collect personal information from other sources. When Paragon collects personal information about individuals directly from them, except when their consent to the collection is deemed or has otherwise been previously and lawfully obtained, or is not required, we will tell them the purpose for which the information is collected, and the name of a person who can answer questions about the collection.

Why We Collect, Use And Disclose Personal Information

Paragon generally collects, uses and discloses personal information for the following purposes:

· To recruit, hire, manage and terminate our employees;

· To fulfill our legal obligations;

· To manage our relationship with and our obligations to our shareholders, investors, directors, suppliers and customers. Paragon is required by applicable laws and regulatory authorities to collect, use and disclose certain information with respect to its shareholders, investors and directors;

· Personal information from other individuals may be collected when such individuals contact Paragon for a variety of reasons personal to them. For example, if you contact us with an inquiry, we will use the information you provide to assist us in responding to you and communicating with you.

· To provide products and services to you. In the course of doing so, we may disclose your personal information to our service providers so that they may be able to assist us in providing products and services to you. We will require that those service providers not otherwise use or disclose your personal information.

· If you request our newsletter, we will use your personal information to deliver the newsletter to you.

Retention and Destruction Of Personal Information

The law allows us, for legal or business purposes, to retain personal information for as long as is reasonable. Upon expiry of an appropriate retention period, bearing in mind reasonable legal and business requirements, personal information will either be destroyed in a secure manner or made anonymous.

Should consent to our collection, use, disclosure or retention of personal information be revoked by the individual in question, the law also allows us to continue to retain the information for as long as is reasonable for legal or business purposes. In the event that revocation of consent may have consequences to the individual concerned, we will advise the individual of the consequences of revoking their consent where it is reasonable in the circumstances to do so.

Where personal information is used to make a decision about an individual, it is our policy to retain such personal information for at least a year after the decision has been made.

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate, up to date, and complete.

Security

We recognize our legal obligations to protect the personal information we have gathered about individuals. We have therefore made arrangements to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information. These arrangements may include physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access.

Requests for Access

Generally, privacy law permits individuals to submit written requests to us to provide them with:

* access to their personal information under the control of Paragon;

* information about the ways in which their personal information under the control of Paragon has been and is being used; and

* the names of organizations or persons to which personal information has been and is being disclosed by Paragon.

Requests for access are subject to the following:

· Any requests must be in writing.

· We do not accept such requests or respond to such requests via email.

· In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.

· We will respond to requests in the time allowed by privacy law, which is generally 30 days.

· We will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible.

· All requests may be subject to any fees and disbursements the law permits us to charge.

· Where appropriate to do so, we may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.

Please note that an individual/'s ability to access his or her personal information under our control is not an absolute right. Generally, privacy law provides that Paragon must not disclose personal information where:

* the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;

* the disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;

* the disclosure would reveal personal information about another individual; or

* the disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.

Generally, privacy law also provides that Paragon may choose not to disclose personal information in situations including but not limited to:

* the personal information is protected by solicitor-client privilege;

* the disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization; or

* the personal information was collected by Paragon for an investigation or legal proceeding and the associated proceedings and appeals have not been completed.

Responses to Requests

Our responses to requests for access to personal information will be in writing, and will confirm:

· whether we are providing all or part of the requested information,

· whether or not we are allowing access or providing copies, and,

· if access is being provided, when and how that will be given.

· if access to information or copies are refused by us, we will provide written reasons for such refusal and the basis on which that refusal is based. We will also provide the name, position title, business address and telephone number of an individual at Paragon who can answer questions about the refusal, and particulars of how the requesting individual can ask the applicable governmental Privacy Commissioner to review our decision. In order to receive a response to such a request, the individual must provide us with sufficient information to locate their record, if any, and to respond to them.

Requests for Correction

Generally, privacy law permits individuals to submit written requests to us to correct errors or omissions in their personal information that is in our control. If an individual alleges errors or omissions in the personal information in our control, we will either:

* correct the personal information and, if reasonable to do so, and if not contrary to law, send correction notifications to any other organizations to whom we disclosed the incorrect information in the year before the date the correction was made; or

* decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

Contacting Paragon

If you have any questions with respect to our policies concerning the collection, use, disclosure or handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, or if you are dissatisfied with how we handle your personal information, please contact our Privacy Officer at:

Attention:Privacy Officer
Address:Paragon Pharmacies Limited
Unit 8, 2604 Enterprise Way
Kelowna, BC
V1X 7Y5
Fax:(250) 868-8402