Last Update: June, 2024

INTRODUCTION AND DEFINITIONS

This privacy policy (the “Privacy Policy”) constitutes an agreement between you, or if you are under the age of majority in your local jurisdiction, your parent or legal guardian (“user”, “you” or “your”) and Trio Labs Inc. and its affiliates and subsidiaries (collectively, “Trio Labs”, “us”, “our” or “we”). Trio Labs is dedicated to protecting the privacy rights of our users. This Privacy Policy describes how Trio Labs collects, protects, uses, and discloses information and data created in the course of your access to and use of the Site, Content and/or Services (each as defined below). Please note that this Privacy Policy applies only to information collected through the Site, Content, and/or Services – it does not apply to information you disclose to Trio Labs through offline correspondence or personal contact with Trio Labs representatives.

If you have any questions or concerns after reading this, please email us at: [email protected].

Definitions:

“Content”: Any expression fixed in a tangible medium, including text, comments, video, audio, images, graphics, designs, logos, trademarks, information, data, software, and any intellectual property therein.

“Minor”: A person under the age of majority in the jurisdiction where Trio Labs is located.

“Patient Representative”: A person authorized to act on the patient’s behalf to manage the patient’s prescriptions and Services.

“Services”: All services made available by Trio Labs, including those accessed through the Content or the Site.

“Site”: www.triolab.ca, its related webpages, and Trio Labs’ mobile applications.

“User Generated Content” or “UGC”: Any Content submitted, created, uploaded, transferred, or otherwise made available by users, including messages, information, images, and data.

ACCEPTANCE OF TERMS AND REVISIONS

By accessing the Site, submitting information to us, or downloading, installing, or using any of the Content or Services, you consent to the collection and use of your information by Trio Labs in accordance with this Privacy Policy. If you do not accept this Privacy Policy, you must not submit information to or register an account with us, access the Site, or download, install, or use any of the Content or Services.

We reserve the right to revise this Privacy Policy at any time. We will give you notice of such revisions by posting the revised Privacy Policy at www.triolab.ca/privacy. It is your responsibility to ensure that you are aware of the current Privacy Policy when you access or use the Site and/or Services. If you continue to access or use any of the Site and/or Services after any revisions to this Privacy Policy are posted, you will be deemed to have accepted those revisions.

TYPES OF INFORMATION WE COLLECT

There are two types of information we may collect through your access to and use of the Site, Content, and/or Services:

1. Personal Information: Information about an identifiable individual (including any “Personal Information” as defined in PIPEDA). This includes, but is not limited to, name, email address, residential address, precise geolocation, telephone number, date of birth, health number, medication and prescription information, allergies, medical history, gender, insurance information, payment information, and user name. Health-related services may also require physical and mental health information, family medical history, existing medications, allergies, prescription information, primary physician information, and health benefits information.
2. Non-Personal Information: Information that does not identify you and cannot be used to contact you personally. This includes date of birth, age, gender, postal code, non-precise geolocation (e.g., city), and Usage Data (anonymous data associated with your computer, mobile device, and/or media system platform).

If you connect your Google, Apple, or other third-party accounts with us, we may collect both personal and non-personal information from those accounts to provide our services. This is dependent on the privacy policies or settings for those accounts. We will not share the data collected with any third party. You may choose to limit what data you provide from such third parties to Trio Labs.

APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies only to the information that Trio Labs collects and uses, or is supplied, through the access to and use of the Site and/or Services. Trio Labs is not responsible for the actions of any third parties, the content of their websites, the use of information you provide to them, or any products or services they may offer. Any information you disclose to a third party is dealt with in accordance with the privacy policies adopted by each of those third parties.

The Site, Content, and/or Services may contain links to third-party websites (the “Linked Sites”) that are not controlled or operated by Trio Labs. Linked Sites are offered solely as a convenience to you and do not constitute our sponsorship or endorsement of, or affiliation with, those third parties. The Linked Sites are maintained by third parties who have their own privacy policies and their own terms and conditions of use. This Privacy Policy does not apply to any of the Linked Sites, and Trio Labs is not responsible for any information disclosed to or collected by those Linked Sites or for the privacy practices of any operators or sponsors of the Linked Sites.

CONSENT

BY SUBMITTING PERSONAL INFORMATION TO TRIO LABS, YOU AGREE THAT TRIO LABS MAY COLLECT YOUR PERSONAL INFORMATION AND YOU CONSENT TO THE USE, DISCLOSURE, AND TRANSFER OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain purposes identified herein at any time by contacting Trio Labs through the contact details provided below. If you refuse or withdraw your consent, you acknowledge that Trio Labs may not be able to provide you or continue to provide you with certain Services which may be of value to you.

COLLECTION OF INFORMATION

We may collect information (including Personal Information) as follows:

Information You Provide to Us: When you open an account with us, request support, or take steps that require the submission of information; we may collect information such as your name, email address, telephone number, date of birth, gender, health number, allergies, medical history, insurance and payment information, employment status, occupation, and username. This information is necessary for verifying your identity, fulfilling your orders, contacting you regarding your prescription, and providing you with the Services.

Information Provided by Your Patient Representative or User for Whom You Will Be a Patient Representative: If a user wishes to have you act as the user’s Patient Representative for managing prescriptions and Services, we may collect information about you from that user, such as your name, email address, telephone number, date of birth, and gender. Similarly, if another user wishes to act as a Patient Representative for you, we may collect your name, email address, telephone number, date of birth, and gender.

Social Media Sites: If you choose to connect to our Site and/or Services through a third-party social network, we may collect information from your profile on such third-party social networks, such as your name, username, photograph, gender, and date of birth.

Purchases: When you or your Patient Representative make purchases through our Site and/or Services, our payment processor will collect your credit card information. We do not collect or store your credit card information. Other information, such as your insurance information, policy numbers, and group plan information, will be stored and processed by us or any pharmacy software provider we may partner with.

Prescriptions: When you or your Patient Representative fill prescriptions through our Site and/or Services, you or your Patient Representative will provide us with your prescription information, including the medication requested, amounts, and information regarding your physician or other prescribing professional. We will use this information to fill your prescription as required. This information will be stored, processed, and shared with the relevant prescription drug information system as required by applicable law in your jurisdiction.

Public Forums: If you choose to make use of any public forum, blog, comment section, or chat function, we may collect any information you may disclose through such means.

In-Media Communications: If you choose to send a message to us through our message, chat, post, SMS, email, or other function, we may collect any information you may disclose through such means to facilitate the communication.

Push Notifications: If you choose to enable push notifications, we may use your information, such as a device ID or email address, to send push notifications to your device.

Location: We may collect precise geolocation information, provided that you will either be informed of such practice or be prompted to allow or disallow such feature.

Visiting Our Site: We will not collect any Personal Information from you simply by virtue of your visiting our Site; we only collect Personal Information if you or your Patient Representative choose to submit it to us. We do, however, collect Non-Personal Information such as Usage Data whenever you use our Site and/or Services.

Cookies: We may use cookies or similar technologies to collect information. If you do not wish to accept cookies, you have the option of blocking or disabling cookies. However, please be aware that some of our Site, Content, and/or Services will not function properly if you do so.

PUBLIC INFORMATION INCLUDING USER GENERATED CONTENT

UPDATES AND PUSH NOTIFICATIONS

We may occasionally send you updates, patches, and related push notifications that may be of importance to you. If you do not wish to receive updates, patches, and notifications, you should discontinue use of our Site, Content, and/or Services or disconnect your computer or device from the Internet.

If you do not wish to receive push notifications, you can disallow this function through the settings on your mobile device.

DISCLOSURE OF INFORMATION

We will not transfer your Personal Information to third parties, except for our subsidiaries, affiliates, and business partners that we engage to provide services on our behalf, such as web hosting services, credit card payment processing, provincial/private health plan coverage, pharmacy software providers, order processing, and delivery, provided that such third parties have agreed to comply with legally required privacy standards and agree to use the information only for the purposes disclosed at the time of collection or for a use consistent with that purpose. Trio Labs will only provide those third parties with the Personal Information that they need to deliver the services to Trio Labs or on Trio Labs’ behalf.

We will also provide Personal Information to the relevant prescription drug information system as required by applicable law in your jurisdiction. We may also contact your physician or the prescribing professional if additional information regarding your prescription is required and may disclose or obtain Personal Information through such contact.

We may have the need to disclose your Personal Information to a third-party licensed pharmacy and a prescribing physician to fill your prescription(s). We may also disclose your Personal Information to your provincial and/or private health plan as a matter of convenience for payment of your prescription purchases.

We may also disclose your Personal Information to a third-party vendor whose products or services you have requested to deliver those products and services to you. Such third parties may keep and use your Personal Information whether or not you purchase their products or services. Your Personal Information will be subject to their privacy policies, so you should contact them directly for information or to voice your concerns about their policies.

Notwithstanding the foregoing, we reserve the right to disclose information, including Personal Information, if we reasonably believe that we are required to do so by law or legal process or if we are otherwise requested by any law enforcement officer or agency acting under color of law. In addition, we reserve the right to disclose Personal Information and Non-Personal Information to:

Enforce the Terms of Use.

Investigate and/or take action against unlawful activity, suspected abuse, or unauthorized use of the Site and Services.

Protect and defend the rights or property of Trio Labs.

Act in urgent circumstances, including medical emergencies, to protect the safety or security of the public or users of the Site and/or Services.

Subject to applicable privacy laws, we may also disclose your information (including Personal Information) in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information. If we do so, we will notify you that such a transaction has taken place and that your Personal Information has been disclosed.

We may also share aggregate or anonymized information, including Personal Information, about you with service providers, business partners, and other third parties, to the extent permitted by applicable law.

We may sell, rent, or share your Usage Data and other Non-Personal Information with third parties who assist us with our operations, such as administration, analytics, research, and optimization, and with our business partners to serve more relevant advertisements tailored to you.

PROTECTION OF YOUR INFORMATION

As required by applicable privacy laws, Trio Labs has implemented reasonable physical and technical measures to protect the information we collect or are provided with from unauthorized access and against loss, misuse, or alteration by third parties. We work hard to protect your data from unauthorized access, alteration, disclosure, or destruction. Here are the measures we take to ensure the security of your information:

• We use encryption to keep your data secure while in transit and at rest.

• We employ a range of security measures like multifactor authentication and masking to help us protect your account.

• We constantly review our information collection, storage, and processing practices, including our subprocessors, to prevent unauthorized access to our systems.

• We undergo security training and compliance audits and adhere to the regulations put forth by law and the college of pharmacies.

• We do not warrant or represent that your information will be protected against loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE EXPRESSLY DISCLAIM ANY GUARANTEE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION.

For further information on how we safeguard information we collect or are provided with, visit www.triolab.ca/security or contact us via email at [email protected].

RETENTION OF YOUR INFORMATION

The data and information that we collect will be stored and maintained by Trio Labs or our third-party service providers until you delete it or instruct us to delete it.

Currently, Trio Labs or our third-party service providers retain and store information collected by, or provided to, us in the cloud and on secure servers in Canada. As some of our third-party service providers may retain and store information received from users (including Personal Information) outside of Canada, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other provinces or foreign jurisdictions may be entitled to access users’ information.

ACCOUNT SECURITY

If you access our Site and/or use any of our Services, you are responsible for protecting the confidentiality of your account password and elected codes, and for restricting access to your computer, device, or media system platform, and you agree to accept responsibility for all activities that occur under your account. Please notify us immediately if you detect a suspected breach or misuse of your account.

ACCESS AND ACCURACY

Trio Labs will use commercially reasonable efforts to provide you access to your Personal Information (to the extent we are in possession of any) if you submit your request for access via [email protected]. Subject to applicable law, Trio Labs reserves the right to deny access to your Personal Information on any of the following grounds:

When denial of access is required by law.

When granting you access is reasonably likely to negatively impact other people’s privacy.

When granting access is, in our judgment and acting reasonably, cost prohibitive.

When we have reason to believe that such requests are frivolous or made in bad faith.

You are responsible for ensuring that all information created through your access to and use of the Site and/or Services is accurate, reliable, and complete, and you acknowledge and accept that the use of such information is at your own risk. We ask that you keep the Personal Information that you provide to us current and correct. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person. If you believe that the Personal Information maintained by Trio Labs about you is inaccurate or incomplete, you may notify us by describing in detail any inaccuracies or omissions via email at [email protected]. Following receipt of a properly submitted notice, we will, within a reasonable time period and acting in our sole discretion, use commercially reasonable efforts to either:

1. Amend or correct your Personal Information to reflect corrected or additional information provided by you, or
2. In connection with your Personal Information, make note of any claimed inaccuracies or omissions reported in the notice submitted by you.

OUR POLICY REGARDING CHILDREN

Trio Labs recognizes the privacy interest of children, and our Site, Content, and/or Services are not intended for children under the age of majority in your jurisdiction, and we do not target our Site, Content, and/or Services to children under the age of majority. Trio Labs does not knowingly collect or use any Personal Information from children under the age of majority unless provided by a parent or guardian using the Site and/or Services on behalf of such minor. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, please contact us at [email protected]. We will delete such information from our files within a reasonable time.

GOVERNING LAW

Those who choose to use or access the Site and/or Services from outside Canada do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Notwithstanding the foregoing, and recognizing the global nature of the Internet, each viewer and user shall comply with all local rules regarding online conduct and submission of acceptable materials. This Privacy Policy is governed and interpreted pursuant to the laws of the province where your dispensing pharmacy is located and the federal laws of Canada applicable therein, without regard to principles of conflicts of law that would impose the law of another jurisdiction, and you accept and submit to the exclusive jurisdiction of the courts located within the province where your applicable dispensing pharmacy is located.

INTERNATIONAL TRANSFER

To the extent permitted by applicable law, we may transfer information that we collect about you to third parties across international borders and from your jurisdiction to other jurisdictions around the world for storage on the servers that store and manage certain of the information and data that we collect. To the extent required by applicable laws, Trio Labs will maintain and store your personal information in Canada or within your jurisdiction and not transmit such information across international or jurisdictional borders. Please note that these countries and jurisdictions may not have the same personal information protection laws as your own jurisdiction, and you consent to the transfer of information over international borders and the use and disclosure of information about you, including Personal Information, as described in this Privacy Policy.

QUESTIONS OR COMMENTS

We welcome questions or comments about this Privacy Policy. Please direct any questions or comments to the individual below who oversees Trio Labs’ compliance with privacy requirements:

Trio Labs Inc. Attention: Privacy Officer Address:
391B Matheson Blvd East
Mississauga, ON, L4Z 2H2
Toll-free phone number: 833-533-TRIO
Local phone number: 289-312-1599
Fax number: 833-333-1599
Email: [email protected]
Website: www.triolab.ca